Percentage of individuals with food insecurity, the metric titled, “Food Insecurity,” came from Feeding America’s Map the Meal Gap 2022. 4 This data has a two year lag, meaning that the data used for the 2024 WIC Affirmative Action represents 2022 food insecurity rates. According to the methodology outlined in the Map the Meal: Technical Brief county-level food insecurity data is drawn from the American Community Survey (ACS), except for county unemployment data, which are drawn from the Bureau of Labor Statistics (BLS) and are calculated using the following variables: unemployment rates, median income, poverty rates, homeownership rates, percent of the population that is Black, and percent of the population that is Hispanic, disability rates, and an adjusted poverty variable that excludes college students to better reflect the socio economic status of communities with sizeable student populations. The metric, “People Not Accessing WIC that are Eligible,” was sourced from the Research Profile of WIC Eligibility and Participation in Montana, 2022: Evidence from Administrative Records and the American Community Survey. Data from this source was pooled from 2020-2022.5 It is important to note that additional calculations are required to calculate percent of people not accessing WIC that are eligible. The data source utilized provides the percent of people eligible for WIC and out of those that are eligible, the percent accessing WIC. For the purposes of this plan, the percent accessing WIC from the whole county was calculated in order to subtract it from the percent eligible to get the true percent of those accessing WIC that are eligible per county. The six metrics were standardized by statewide proportions as follows: Once a standardized score for all six metrics was established across each county, an overall standardized score is assigned to each county by taking the mean score across all six metrics. The

resulting overall standardized score indicates the relative need of each county. Counties with standardized scores of less than one have a greater need for WIC support than the statewide average; counties with standardized scores of greater than one have lower needs than the statewide average. III. Description of Ranking System To establish ranking among counties, the overall standardized scores were ranked from smallest (highest need county) to largest (county with least need). IV. Affirmative Action Plan Ranking The Affirmative Action Plan rankings would be used as one tool among many to assist in the expansion of WIC in Montana, when and if funds become available. If funds were available, new agencies or satellites would be opened in descending order from the top in the Plan, with no WIC agency receiving funds until the eligible agencies above were funded. V. Considerations for Future Metrics Various metrics have been used throughout the years to determine the Affirmative Action ranking for WIC. Below are several considerations to make when choosing metrics in future years. a. There was significant suppression in the “Low Birth Rate” metric in the 2023 Affirmative Action plan. The MT Office of Vital Statistics changed their suppression guidelines in 2023 and has resulted in less metric suppression. This metric has been retained for future use. b. Due to the significant amount of data suppression and lack of relevancy to program objectives, the “Teen Pregnancy” (15-19 years) rate was replaced with “People Not Accessing WIC that are Eligible” provided by the Census. This metric also has significant suppression but is in line with programmatic goals. c. The “Births Covered by Medicaid” metric was replaced with “Infants on Medicaid by First Birthday.” This is a more accurate indicator of the WIC-eligible population in a county, since births paid for by Medicaid is often a low estimate of the true proportion of Medicaid-covered births. d. At several points in the past, the MT Medicaid Office has completed a project that matches data between participants on Medicaid and the Census to more accurately estimate the percentage of people who are eligible for WIC in each county. This data has not been updated recently and was not included in this Affirmative Action table. Instead, similar data has been calculated using the Research Profile of WIC Eligibility and Participation in Montana, 2022: Evidence from Administrative Records and the American Community Survey. Data from this source utilizes statistical models to provide estimates. These estimates will be compared to the Montana Medicaid matching findings if the project is conducted again. e. Plan methodologies will be reviewed every five years to ensure efficacy. References

1. Kotelchuck M. An Evaluation of the Kessner Adequacy of Prenatal Care Index and a Proposed Adequacy of Prenatal Care Utilization Index. Am J Public Health. 1994;84(9). 2. MT Department of Public Health and Human Services (DPHHS), Office of Vital Statistics. 2019- 2023. Provided to WIC March 2024. 3. MT Department of Public Health and Human Services (DPHHS), Montana Medicaid. 2019-2023. Provided to WIC April 2024. 4. Feeding America: Map the Meal Gap Food Insecurity in the United States. 2022. https://map.feedingamerica.org/ Accessed May 2024. 5. Center for Economic Studies, US Census Bureau. Research Profile of WIC Eligibility and Participation in Montana, 2022: Evidence from Administrative Records and the American Community Survey. July 2024.

Overall Rank % Standardized % Standardized % Standardized % Standardized % Standardized % Standardized State Average 89.9% 77.9% 49.00% 11.70% 6.6% 25.1% COUNTY Roosevelt 85.5% 0.951 44.9% 0.577 81.3% 0.367 18.7% 0.921 7.4% 0.991 42.6% 0.766 0.762 1 Big Horn 87.0% 0.968 38.9% 0.500 88.0% 0.236 16.6% 0.945 6.0% 1.006 18.5% 1.088 0.790 2 Blaine 86.7% 0.964 50.6% 0.650 73.5% 0.519 16.4% 0.947 9.1% 0.973 36.6% 0.847 0.817 3 Glacier 86.2% 0.959 53.0% 0.681 81.4% 0.365 19.4% 0.913 7.9% 0.986 25.1% 1.000 0.817 4 Wheatland 88.5% 0.984 59.8% 0.768 77.0% 0.451 14.5% 0.968 8.8% 0.976 32.3% 0.904 0.842 5 Rosebud 88.8% 0.988 45.2% 0.581 71.3% 0.562 15.9% 0.952 5.6% 1.011 19.2% 1.078 0.862 6 Pondera 88.6% 0.986 58.3% 0.749 73.8% 0.513 15.4% 0.958 9.7% 0.967 25.1% 1.000 0.862 7 Hill 89.7% 0.998 52.2% 0.671 68.6% 0.617 12.5% 0.991 5.5% 1.012 25.1% 1.000 0.881 8 Toole 89.4% 0.994 44.3% 0.569 58.6% 0.813 12.0% 0.997 9.5% 0.969 25.1% 1.000 0.890 9 Phillips 91.0% 1.012 61.4% 0.789 72.0% 0.548 10.0% 1.019 6.6% 1.000 25.1% 1.000 0.895 10 Liberty 90.7% 1.009 64.8% 0.832 66.7% 0.654 17.4% 0.935 6.5% 1.001 25.1% 1.000 0.905 11 Golden Valley 91.4% 1.017 53.4% 0.686 58.6% 0.811 13.4% 0.981 6.6% 1.000 29.0% 0.948 0.907 12 Sanders 91.8% 1.021 67.8% 0.871 63.0% 0.725 14.9% 0.964 3.6% 1.032 33.6% 0.887 0.917 13 Treasure 97.9% 1.089 72.9% 0.936 72.9% 0.531 10.9% 1.009 6.6% 1.000 28.8% 0.950 0.919 14 Ravalli 89.5% 0.996 82.1% 1.055 51.8% 0.946 11.2% 1.006 6.5% 1.001 57.7% 0.565 0.928 15 Meagher 87.8% 0.977 65.6% 0.843 57.8% 0.828 11.0% 1.008 10.0% 0.964 28.4% 0.957 0.929 16 Mineral 91.5% 1.018 80.7% 1.037 69.7% 0.595 13.6% 0.978 8.0% 0.985 25.1% 1.000 0.935 17 Lincoln 90.4% 1.006 77.4% 0.994 68.6% 0.616 15.6% 0.956 6.3% 1.003 20.1% 1.067 0.940 18 Lake 87.7% 0.976 74.4% 0.956 68.7% 0.614 13.8% 0.976 7.2% 0.994 12.4% 1.170 0.948 19 Musselshell 91.3% 1.016 63.9% 0.821 55.4% 0.874 11.8% 0.999 8.2% 0.983 25.1% 1.000 0.949 20 Custer 91.4% 1.017 84.9% 1.091 56.2% 0.860 12.6% 0.990 5.0% 1.017 45.4% 0.728 0.950 21 Chouteau 91.5% 1.018 63.6% 0.817 50.0% 0.980 12.3% 0.993 6.5% 1.001 25.1% 1.000 0.968 22 Silver Bow 86.2% 0.959 81.0% 1.040 56.5% 0.854 13.5% 0.980 9.6% 0.968 18.1% 1.093 0.982 23 Teton 86.9% 0.967 71.4% 0.917 51.3% 0.955 11.6% 1.001 8.0% 0.985 18.1% 1.094 0.986 24 Deer Lodge 89.5% 0.996 81.9% 1.052 50.7% 0.967 17.5% 0.934 8.6% 0.979 25.1% 1.000 0.988 25 Judith Basin 91.7% 1.020 76.9% 0.988 47.7% 1.025 12.8% 0.988 4.6% 1.021 30.6% 0.927 0.995 26 Valley 90.3% 1.004 73.3% 0.942 52.9% 0.923 11.8% 0.999 4.2% 1.026 18.7% 1.085 0.996 27 Powell 91.2% 1.014 78.2% 1.004 51.3% 0.956 10.7% 1.011 5.5% 1.012 25.1% 1.000 1.000 28 Garfield 95.1% 1.058 69.1% 0.888 45.7% 1.065 9.7% 1.023 6.6% 1.000 25.1% 1.000 1.006 29 Yellowstone 90.5% 1.007 80.3% 1.031 49.2% 0.996 10.5% 1.014 6.5% 1.001 25.1% 1.000 1.008 30 Cascade 89.4% 0.994 76.4% 0.981 44.6% 1.086 12.0% 0.997 6.0% 1.006 25.1% 1.000 1.011 31 Stillwater 91.2% 1.014 84.4% 1.084 39.4% 1.189 9.7% 1.023 5.3% 1.014 43.9% 0.749 1.012 32 Jefferson 89.9% 1.000 82.8% 1.064 35.8% 1.260 8.9% 1.032 6.1% 1.005 42.5% 0.767 1.021 33 Flathead 91.1% 1.013 86.0% 1.105 49.3% 0.994 10.0% 1.019 6.4% 1.002 25.1% 1.000 1.022 34 Beaverhead 92.0% 1.023 83.1% 1.067 47.6% 1.028 11.4% 1.003 4.9% 1.018 25.1% 1.000 1.023 35 Fergus 88.2% 0.981 82.1% 1.055 42.3% 1.131 13.0% 0.985 7.0% 0.996 25.1% 1.000 1.025 36 Broadwater 86.8% 0.966 77.8% 0.999 39.5% 1.186 10.5% 1.014 7.8% 0.987 25.1% 1.000 1.025 37 Petroleum 96.7% 1.076 76.7% 0.985 50.0% 0.980 8.0% 1.042 0.0% 1.071 25.1% 1.000 1.026 38 Granite 96.2% 1.070 72.3% 0.929 42.0% 1.138 12.9% 0.986 6.6% 1.000 21.9% 1.043 1.028 39 Carbon 90.8% 1.010 75.4% 0.969 41.8% 1.142 11.0% 1.008 5.8% 1.009 20.8% 1.057 1.032 40 Sweet Grass 90.6% 1.008 79.9% 1.026 41.7% 1.143 8.5% 1.036 7.9% 0.986 25.1% 1.000 1.033 41 Madison 90.9% 1.011 78.5% 1.008 38.0% 1.215 6.7% 1.057 5.8% 1.009 31.2% 0.919 1.036 42 Sheridan 91.6% 1.019 72.7% 0.934 43.7% 1.104 10.7% 1.011 3.6% 1.032 15.3% 1.131 1.038 43 Wibaux 84.8% 0.943 84.8% 1.089 30.4% 1.364 12.7% 0.989 6.6% 1.000 36.5% 0.848 1.039 44 Daniels 92.3% 1.027 68.8% 0.884 30.8% 1.357 11.7% 1.000 6.6% 1.000 23.6% 1.021 1.048 45 Park 90.1% 1.002 85.0% 1.092 38.0% 1.216 10.7% 1.011 6.9% 0.997 25.1% 1.000 1.053 46 2024 Montana WIC Affirmative Action Table Term Births Adequate/Adequate+ Prenatal Infants on Medicaid by 1st Percentage Food Insecurity*** LBW Infants* Percent of People Not Accessing

Prairie 93.9% 1.044 73.5% 0.944 40.8% 1.160 16.0% 0.951 6.6% 1.000 8.5% 1.222 1.054 47 Lewis and Clark 90.5% 1.007 78.3% 1.006 41.9% 1.139 10.2% 1.017 7.1% 0.995 11.0% 1.189 1.059 48 Missoula 90.0% 1.001 85.2% 1.094 43.0% 1.117 11.2% 1.006 6.6% 1.000 13.4% 1.156 1.062 49 Dawson 91.1% 1.013 82.4% 1.058 42.0% 1.138 10.2% 1.017 5.2% 1.015 14.2% 1.145 1.064 50 Fallon 90.1% 1.002 85.0% 1.092 35.2% 1.271 10.8% 1.010 3.8% 1.030 23.4% 1.023 1.071 51 Powder River 93.2% 1.037 79.5% 1.021 29.6% 1.381 11.6% 1.001 5.7% 1.010 25.1% 1.000 1.075 52 McCone 94.0% 1.001 78.8% 1.012 25.0% 1.471 9.4% 1.026 4.0% 1.028 25.1% 1.000 1.090 55 Carter 97.3% 1.082 77.3% 0.993 26.7% 1.438 13.9% 0.975 6.6% 1.000 25.1% 1.000 1.081 53 Gallatin 90.6% 1.008 86.6% 1.112 29.9% 1.375 9.0% 1.031 6.9% 0.997 25.1% 1.000 1.087 54 Richland 90.0% 1.001 83.4% 1.071 29.8% 1.376 10.3% 1.016 5.2% 1.015 17.4% 1.103 1.097 56 * Source: OESS, MT DPHHS, data 2019-2023 ** Source: OESS and Medicaid, data 2019 - 2023 *** Source: Feeding America: Map the Meal Gap 2022 **** Source: Cenusus MT Profile, data 2020-2022. Note: Suppression in this data set could be been from either Eligibility, Access (of Eligility), or both data sets. ***** - numbers too small for precise rates, rates suppressed. Using state average in place of county average for this measure.

Alternate Means of Signature for eWIC Card

I, have received the following eWIC Card. Primary Card Holder Name eWIC Card Number Signature of Primary Cardholder Date INSTRUCTIONS: Scan completed form into appropriate participant folder(s). Alternate Means for Signature of eWIC Card October 2025

Montana WIC Program Anemia Cut-Off Values and Timing Chart 1998 CDC Guidelines Category Age *HGB (<g/dL) *HCT (<%) Certification Mid-Certification Follow-Up Appointment Infant 9-11 mos. 11.0 33 Yes N/A Yes - if it has not yet been collected during this age range No - if completed at certification 9-11 months (even if low at initial check) Child 1 to < 2 yr. 11.0 33 Initial Cert: Yes (always) Yes (always) No Subsequent Cert: • No- if infant was checked at 9-11 mo. (even if it was low) • Yes- if infant was not checked at 9-11 mo. Child 2-5 yrs. 11.1 33 Yes Yes-if low at certification No No- if normal at certification Woman See Below Yes No Yes- if low at certification Non-Pregnant 12 to < 15 yrs. 11.8 36 15 to < 18 yrs. 12.0 36 ≥18 yrs. 12.0 36 Pregnant 1st Trimester 11.0 33 2nd Trimester 10.5 32 3rd Trimester 11.0 33 * The Cuff -Off Values for hgb,/hct. used on this form are “at sea-level, non-smoking” and are based on the participant’s category and age. SWEB has the adjustments for altitude and smoking programed in.

___________________________________________________________________________________ ___________________________________________________________________________________ Montana WIC Application for Lo

cal Agency Programs I. II. III. Instructions: A. Contact the State WIC Director to discuss intent to apply for a new local agency program or clinic within an existing program. B. Please answer all questions completely (may attach additional pages or references if needed). C. Use the most current available applicable. Applicant Information: A. Applying Agency Name: ___________________________________________________________ B. Address: __________________________________________________________________________ C. Telephone: ________________________________________________________________________ D. Name, title and address of responsible official: _______________________________________ E. Applying for (check one):  New Local Agency (Region)  New clinic within existing region If this application is for a satellite/outlying clinic, provide a brief explanation of why an additional clinic is desired or needed: F. Type of Agency:  Public/Government Entity  Private, Non-profit  IRS Tax Exempt #: __________________  IRS application pending- Date submitted  Tribal  Other: ____________________________ / /____ Please address the following questions related to administrative feasibility: A. Are commissioners, Health Officer, and/or management staff at the local site supportive of starting an independent/new WIC clinic? B. Is there adequate infrastructure to support the WIC clinic? C. What equipment will need to be purchased to begin the operation of a new clinic (i.e., computer, scales, measure/stature boards, hemoglobin testing machine, office furniture, storage cabinets, etc.)? What costs are associated with this and is there existing equipment that could be shared with adjoining entity? Montana WIC Application For Local Agency Programs October 2025

Montana WIC Application for Local Agency Programs D. If this application is for a new satellite/outlying clinic, are there enough funds to operate an additional clinic within the existing grant? E. When do you anticipate being ready to open a WIC clinic? F. How many days per month and hours per day do you anticipate offering WIC services? IV. Health Services: A. Is there currently pediatric and/or perinatal care available in your agency or community? If yes, describe: If no, describe your plans to ensure WIC participants have access to these services: B. Describe your plans to refer Program participants to a public agency or private provider for follow-up on identified health problems, including the procedure for feedback from the public or private provider. V. Nutrition Services: A. Provide the name of the individual who will act as Competent Professional Authority (CPA). A CPA is an individual on the staff of the local agency authorized to determine an applicant eligible for participation, determine nutritional risk and prescribe supplemental foods (see current State Plan for criteria) If no one is currently on staff who meets the criteria as a CPA, what are your plans for recruitment? B. What do you anticipate necessary FTE(s) to be? List position title and anticipated FTE(s): C. Is there a Registered Dietitian (RD) available to work with high-risk participants? Y N Note: if an RD is not available in your agency, the State may deduct some funds from your contract to provide coverage by another local agency (remote RD). VI. Socio-Economic/Vital Statistics: A. What will be your service area (geographic boundaries)? B. What is the service area population? C. What is the service area racial/ethnic composition? 1. White % 2. Black % 3. Hispanic % 4. American Indian % Montana WIC Application For Local Agency Programs October 2025

Montana WIC Application for Local Agency Programs 5. Asian or Pacific Islander % D. What is the median family income in your service area? ______________________ E. Provide information on how you plan to coordinate services with the following programs if available in your location: 1. Office of Public Assistance: 2. Immunizations: 3. Head Start: 4. Home Visiting Program (MIECHV): 5. Substance Abuse Treatment Facilities: 6. Mental/Behavioral Health: 7. Primary Care (pediatric and/or perinatal): VII. Financial Management: A. Request from the State Office and attach a completed budget request and staffing contact form. B. Attach a copy of the most recent financial audit of your agency. C. Attach a completed Financial Questionnaire (State Plan attachment) VIII. WIC Caseload: A. Provide data (if available) on the current and/or projected caseload for the clinic you would like to open _____________ B. Describe your plans for outreach to meet annual requirements for a public announcement of services locally, and effective collaboration/coordination in your community to enroll and retain eligible participants. IX. Physical Location: A. Describe the location where participants will be served. Be specific (i.e. Health Department, City-County Building, Hospital, etc.). Describe office space, size of space, available waiting area, etc. B. Is the space compliant with the Americans with Disabilities Act (ADA) criteria? Y N C. Is the space clean, safe and well-maintained? Y N D. Describe what secure storage is available for eWIC cards, computer equipment, breast pumps, etc. Montana WIC Application For Local Agency Programs October 2025

__________________________________________________________________ ____________________________ ______________________________________________________ Montana WIC Application for Local Agency Programs The applicant agrees to comply with all non-discrimination and American with Disabilities Act (ADA) regulations as described in Part 7 CFR 246.8. The applicant further agrees and assures that if selected, it will comply with the WIC Program Federal Regulations and State Policies and Procedures. The current State Plan may be located at www.wic.mt.gov. The information contained in this application for a WIC Program is true and accurate to the best of my knowledge. Signature of Local Official with Authority to Implement WIC Program Date State Agency Review: Received Date: _____________

Reviewed (name and date): _________________

Decision: Approved Denied On-hold until funds are available

Notification to Applicant (date): _____________

Comments: State Director (or designee) signature: Montana WIC Application For Local Agency Programs October 2025

MONTANA WIC PROGRAM APPROVED FOOD LIST 4/1/2026 No organic unless specified 32oz Container (Quart) Purchase Only Fat Type Specified on Your Benefit Chobani-Lowfat Plain, Nonfat Plain, Whole Milk Plain, Nonfat Vanilla, Nonfat Strawberry Dannon- Whole Milk Plain, Fat Free Plain, Light & Fit Vanilla, Light & Fit Greek Vanilla Essential Everyday- Lowfat Plain, Nonfat Plain Food Club- Greek Whole Milk Vanilla, Nonfat Greek Plain, Lowfat Plain Great Value- Nonfat Plain Greek, Light Greek Vanilla, Plain Nonfat, Nonfat Light Vanilla Kroger- Whole Milk Greek Plain, Lowfat Plain Lucerne-Greek Lowfat Plain, Plain Nonfat, Greek Nonfat Plain, Greek Nonfat Strawberry, Greek Whole Milk Plain Mountain High- Whole Milk Plain, Whole Milk Vanilla, Whole Milk Strawberry, Fat Free Plain, Lowfat Plain, Lowfat Vanilla Stonyfield- Whole Milk Plain, Whole Milk Vanilla, Whole Milk Strawberry, Lowfat Vanilla, Nonfat Plain, Nonfat Plain Greek, Lowfat Plain, Nonfat Vanilla Tillamook- Lowfat Vanilla Bean, Lowfat Plain, Lowfat Strawberry Too Good & Co- Vanilla WinCo- Nonfat Plain Greek, Nonfat Vanilla, Nonfat Plain, Whole Milk Plain Zoi- Whole Milk Plain, Whole Milk Vanilla, Nonfat Plain Quart or Half Gallon Carton or Aseptic Container 8th Continent : Original Flavor Silk Soy Milk: Original Flavor Pacific Natural Foods Ultra Soy Beverage: Original Flavor Specified Brands Only 8-68 oz containers Regular flavor unless specified Best Choice Bran Flakes*, Corn Flakes, or Wheat Flakes* Essential Everyday Bran Flakes*, Corn Flakes, Corn Squares, Crunchy Oat Brown Sugar*, Crispy Rice, Frosted Shredded Wheat*, Rice Squares, or Toasted Oats* Food Club Bran Flakes*, Corn Flakes, Corn Squares, Crisp Rice, Frosted Shredded Wheat*, Rice Squares, Toasted Oats*, or Wheat Squares* General Mills Cheerios* (Plain or Multigrain), Cinnamon Chex, Corn Chex, Kix*, Kix Honey*, Rice Chex, Total Original*, Wheat Chex*, or Wheaties Original* Kashi Honey Toasted Oat Cereal* Warm Cinnamon Oat Cereal* Kellogg’s All Bran Complete Wheat Bran Flakes*, Complete Bran*, Corn Flakes, Rice Krispies, Special K Original, or Frosted Mini Wheats* Kroger Brown Sugar Oat Squares*, Corn Flakes, Crispy Rice, or Toasted Oats* Malt-O-Meal Crispy Rice or Frosted Mini Spooners Our Family Corn Flakes, Crispy Rice, or Frosted Shredded Wheat* Post Grape-Nuts*, Grape-Nuts Flakes*, or Honey Bunches of Oats (Honey Roasted or Vanilla) Quaker Life Multigrain*, Mighty Life Vanilla*, or Oatmeal Squares* (Brown Sugar or Honey Nut) Signature Select Bran Flakes*, Corn Flakes, Corn Pockets, Crispy Rice, Frosted Mini Wheats*, Nutty Nuggets*, Rice Pockets, or Toasted Oats* WinCo Bran Flakes*, Corn Flakes, Crispy Rice, Frosted Shredded Wheat*, or Toasted Oats* No dried fruit No fruit filled or flavored frosting No plain shredded wheat biscuits No individual servings Specified Brands Only 12-28 oz containers (except instant oatmeal) Cream of Wheat Regular Cream of Wheat Whole Grain* Instant Oatmeal* – Best Choice, Food Club, IGA, Our Family, Kroger, Quaker, Signature Select, or WinCo Regular or plain 9-12 oz. box of individual packets only Beech-Nut, Earth’s Best, Gerber, Happy Baby, O Organics, or Wild Harvest 2, 2.5, 4, or 5 oz. containers, jars, twin packs or bulk packaging of acceptable sizes Vegetables & Fruit – single or mixed varieties, all stages May be organic No squeezes or pouches No dinners, desserts, or added cereal No enhancements like DHA Whole grain cereals are marked with * MILK – PASTEURIZED AND FORTIFIED Milk Benefit Issued Types You Can Buy Forms You Can Buy Low-fat (1%) Nonfat (skim) • Regular Cow’s Milk • Lactose-Free Cow’s Milk • Meyenberg Goat’s Milk • Fluid- Refrigerated • Evaporated/Canned • Dried/Powdered No flavor added or enhanced milk *Reduced fat (2%) can Reduced Fat (2%)* • Regular Cow’s Milk • Lactose-Free Cow’s Milk Whole Milk • Regular Cow’s Milk • Lactose-Free Cow’s Milk only be purchased if assigned on your benefit. • Meyenberg Goat’s Milk Organic Milk Approved- These brands ONLY No grassfed or high protein Full Circle Market, Great Value Organic Horizon O Organics Organic Valley Simple Truth Organic Winco Wild Harvest eWIC Conversion Half gallon Quart 0.5 gallons 0.25 gallons 12 oz. evaporated/canned 0.185 gallons (5 cans/gallon) 9.6 oz. dry/powdered 0.75 gallons (4 boxes for 3 gallons) 25.6 oz. dry/powdered 2 gallons 12 oz. powdered goats milk 0.75 gallons (4 cans for 3 gallons) Block, Shredded, Sliced or String Cheese: Regular, low-fat or reduced fat 8, 16, or 32 ounce packages Store Brand, Cache Valley, Country Classic, Crystal Farms, Darigold, Dutch Farms, Frigo, Joseph Farms, Kraft, Premium (Idaho), Sargento, Springfield or Tillamook Cheddar Colby-Monterey Jack Colby Montery Jack Mozzarella Swiss May choose any combination of the choices listed above (i.e. Cheddar Jack) No cheese foods, products, spread, cubed, flavor added (i.e. Pepper Jack), imported, service deli, or imitation cheese products CHEESE – DOMESTIC YOGURT Great Value Bran Flakes*, Frosted Mini- Wheats*, or Rice Crisps IGA Bran Flakes*, Corn Flakes, Corn Squares, Crispy Rice, Frosted Shredded Wheat*, Rice Squares, Tasteeos* HOT CEREAL Only brand, type and size specified on benefit No substitutions at store Oatmeal, Rice, Whole Wheat, Mixed/Multi Grain 8 and 16 oz. containers Earth’s Best or Gerber Plain varieties May be organic No added formula, flavoring, or fruit No squeezes, pouches, jars or packs No enhancements like DHA, prebiotics or probiotics INFANT FORMULA INFANT CEREAL INFANT MEATS May have added broth or gravy May be organic No squeezes or pouches No dinners or meat sticks No enhancements like DHA Available to fully breastfed infant only Beech Nut, Earth’s Best, or Gerber 2.5oz jars Single variety meats only INFANT VEGETABLES/FRUITS SOY BEVERAGE BREAKFAST CEREAL FOR WOMEN & CHILDREN COLD CEREAL

WHOLE WHEAT PASTA 100% Whole Wheat--16 oz. only Barilla, Essential Everyday, Food Club, Gia Russa, Great Value, Hodgson Mill, Italian Chef, Kroger, Our Family, Ronzoni, Signature Select, or WinCo All shapes allowed No enhancements like DHA or omega-3 added PEANUT BUTTER Unflavored regular or natural – smooth or chunky; salted or unsalted (low sodium) 16 – 18 oz. jar Store Brand, Adams, Peter Pan, Jif or Skippy No jelly, honey, honey roasted, chocolate or marshmallow crème added No peanut butter spread No enhanced BEANS, PEAS, AND LENTILS Canned: 15- 16 oz. Dry: 16 or 32 oz packages or bags Any brand Includes split peas and lentils No soup mixes, flavorings or meat added (pork & beans, refried) No cans of green or yellow beans 64 oz. containers or 16 oz. frozen concentrate Any flavor or blend Apple and Eve, Best Choice, Campbell’s, Essential Everyday, Food Club, Great Value, IGA, Juicy Juice, Kroger, Langers, Minute Maid, Motts, Northland, Ocean Spray, Old Orchard, Our Family, Signature Select, Tree Top, V-8, Welch’s, and WinCo No sugar added (including other forms of sugars & syrups) No juice drinks, cocktails or lite juice No Fusion (for example V-8) No DHA added VEGETABLE AND FRUIT BENEFIT May be any brand, size, or variety May be organic May be packaged, pre-cut, sliced, or chopped Garlic and Sprouts are okay No added fats, oils, or sugars (including syrups, sucrose, fructose and dextrose) No dried vegetables or fruits WHOLE GRAIN CHOICES 100% WHOLE WHEAT BREAD 16, 20, or 24 oz. loaf Essential Everyday, Food Club, Franz, Great Value, Kroger, Montana’s Sweetheart, Oroweat, Our Family, Private Selection, Signature Select, Sara Lee Classic, SmartWay, Smith’s, Village Hearth, Wheat Montana, or Winco Montana WIC Program - Approved Food List Questions, call 1-800-433-4298 This institution is an equal opportunity provider. No sauces (like cheese), coatings, or packets of sauces and dressings No spices (like vanilla beans or cinnamon sticks) Cannot be mixed with non-fruit/vegetable items (like nuts, peanuts, pasta, rice, croutons, or wonton strips) No added salts to fruits TORTILLAS – SOFT 8, 16, 20, 24, or 32 oz. Yellow Corn – Mission, La Burrita, or Our Family White Corn – Don Pancho, Guerrero, Kroger, or Our Family Whole Wheat – Best Choice, Don Pancho, Essential Everyday, Great Value, Guerrero, Signature Select, Kroger, Mission or Our Family BROWN RICE Plain, box or bag Regular cooking: 16 or 32 oz. Quick or instant cooking: 14 – 16 oz. Any brand Only the choices listed below may be purchased 16, 20, or 24 oz. loaf Montana’s Sweetheart: 12-Grain, Multigrain with Flax, or Whole Grain Sara Lee Classic: Delightful Healthy Multi-Grain Wheat Montana: Healthy Loaf Cracked 9-Grain, Healthy Loaf High Fiber Flax and Sunflower, Healthy Loaf Montana Multigrain, or Healthy Loaf Seed Lovers Light Tuna – water packed only, light (solid or chunk) Pink Salmon – water packed, may contain bones & skin 5 – 6, 7.5, 12, 14.75, and 20 oz. cans Any brand Plain only No “diet” pack No white, albacore, or yellow fin tuna No red salmon No “vacuum-sealed” packs 16 oz. calcium set blocks Azumaya (extra firm, firm), or House Foods (medium, firm, extra-firm) TOFU CANNED TUNA 100% JUICE LEGUME CHOICES EGGS Fresh herbs allowed No potted plants (like basil) No fresh salsa or guacamole No party trays, fruit baskets, decorative vegetables and fruits, or items from the salad bar May be any package type Vegetables may be regular or low sodium Vegetables may be mixed with legumes May be water or juice packed May be regular or low sodium Plain tomatoes may be diced, whole, crushed, puree, paste Applesauce and Fruit Blends of Applesauce may be in glass jar or plastic container No tubes, squeezes, pouches, boxes, bags, cartons, glass or plastic (except applesauce) No legumes (beans, peas, and lentils)* No vegetables mixed with legumes *Canned or dry legumes can only be purchased as part of the Legume Choice benefit FRESH VEGETABLES & FRUITS FROZEN VEGETABLES & FRUITS CANNED VEGETABLES & FRUITS Download the App: Large—One dozen white “AA” or “A” Any Brand No brown eggs WHOLE GRAIN BREAD

Blood Screening Procedures Form Blood Screening Procedures

October 2025 Prior to Sampling 1. Assemble supplies needed – vial of cuvettes, alcohol pad, lancet, gauze, Band-Aid. 2. Check expiration date of cuvettes. 3. Seat the participant comfortably. If her/his hands are cold, warm the hand from which the sample will be taken. 4. Have the participant remove any rings on the finger to be used. 5. Sanitize or wash hands 6. Put on gloves. 7. Remove only one cuvette for immediate use and close the cuvette vial.

Sampling Technique 1. Use only the middle finger or ring finger for sampling. 2. Clean the puncture site with an alcohol swab and wipe off the alcohol used or allow the finger to air dry. 3. Take the participant’s hand with your thumb on top. Using your thumb in a gentle rocking movement, lightly press the participant’s finger for the sample from the top knuckle to the tip. Gentle pressure should be used. Select the sample site on the top of either side of the finger. Place an appropriate lancet firmly on the finger. Perform the finger stick, maintaining pressure on the finger. 4. Using a dry absorbent pad, wipe away the first two or three good–sized drops of blood. Release pressure on the finger and gently rock it to achieve a good size drop but avoid “milking” the finger. 5. Place the tip of the cuvette into the drop of blood down to the skin. Fill the cuvette completely in one continuous motion. 6. Wipe excess blood on the tip of the cuvette with gauze. Make sure that no blood is sucked out of the cuvette. Check the cuvette for air bubbles. Using a HemoCue® 1. Insert the filled cuvette into the HemoCue® machine. 2. Record the blood hemoglobin value displayed in the window. 3. Dispose of the lancet, cuvette, and other supplies in appropriate containers. 4. Remove gloves and dispose of properly. 5. Wash hands. 6. If another participant is to be tested, select new gloves, and begin the process again. Using a MASIMO- Pronto 1. Select Sensor Size. 2. Place Sensor on Finger. 3. Press SpHb Button. 4. Obtain Results. 5. Clean and Calibrate Per Manufactures Directions.

Breast Pump Log Name, HH ID, Phone # Date Type of Pump Issued (MU, SU, M) Pump # Justification for Issuance of Pump Type & Education Provided (Y/N) Date of Expected Return 3 Day F/U F/U Plan (circle one) Date of Return Initials Cleaned WIC ID: Pump #: Education Provided: Y / N Weekly Monthly HH ID: Ph: WIC ID: Pump #: Education Provided: Y / N Weekly Monthly HH ID: Ph: WIC ID: Pump #: Education Provided: Y / N Weekly Monthly HH ID: Ph: WIC ID: Pump #: Education Provided: Y / N Weekly Monthly HH ID: Ph: WIC ID: Pump #: Education Provided: Y / N Weekly Monthly HH ID: Ph: WIC ID: Pump #: Education Provided: Y / N Weekly Monthly HH ID: Ph: WIC ID: Pump #: Education Provided: Y / N Weekly Monthly HH ID: Ph: Breast Pump Log October 2025

I Breast Pump Loan-Release Form Multi-User Electric request a multi-user electric breast pump from WIC. I have been instructed by on the following topics (please initial below): ______ How to assemble, use and clean the Multi-user pump I’ve been provided ______ How to pump using appropriate pumping techniques ______ How to safely collect and store my breast milk ______ Hand expression (taught or video watched) If I need further information or have questions regarding the use of this breast pump I will contact: Clinic Name Clinic Phone # I understand that (please initial below): ______ I am currently participating in WIC and will continue my participation by keeping my WIC appointments. If I stop participating or I am terminated from WIC, this agreement will be cancelled, and I will return the pump to the clinic. ______ It is my responsibility to protect the pump from theft or loss. I will handle the pump with care and keep it in a safe area. I will lock the pump in my car when traveling and keep it out of sight. ______ It is my responsibility to inform the WIC clinic of any change of address or phone number. ______ If the pump breaks or malfunctions, I must return the pump to the WIC office for repair. ______ This breast pump is for my use only. I will not loan this breast pump to anyone. ______ The WIC Program, its employees, and the Montana Department of Health and Human Services are NOT responsible for any personal damage caused using this breast pump or WIC staff instruction. I AM THE ONLY ONE RESPONSIBLE. ______ This pump is the property of the WIC Program. I must return it by the due date, or it will be reported as stolen. Participant Signature Date Participant ID# __________________________ ___________________________________________________ Participant Phone # Participant Address The participant has been determined to be eligible for a multi-user breast pump for the following reason(s): Issued: Symphony or Lactina WIC Staff Signature Date Breast Pump # Issued Date Pump Issued Expected Return Date INSTRUCTIONS: Scan into the participant’s folder and give a copy to the participant. Breast Pump Loan-Release Form- Multi-User Electric October 2025

Breast Pump Release Form Manual or Single User I, ____________________________have received a single-user breast pump from Medicaid for my most recent pregnancy. □ Yes □ No If yes, is there a problem with that pump? _____________________________________ I have been instructed by (staff member) ______________________________on the following topics (please initial below): Pumping techniques Cleaning, assembly, and care of the pump Storage and use of pumped breast milk I agree to use the pump and its parts as instructed by the staff. I understand this is for personal use only and will not donate, sell, or give away once I am done breastfeeding. If I need further information or have questions regarding the use of this breast pump I will contact: Clinic Name Clinic Phone # I understand that the local WIC Program, the Montana Department of Public Health and Human Services and their employees are NOT responsible for any personal damage caused by the use of this breast pump. I AM THE ONLY ONE RESPONSIBLE. Participant Signature

Date:

Participant ID#

Phone #

Breast Pump Issued: Pump In Style (electric) Harmony (manual) The participant has been determined to be eligible for a single-user breast pump for the following reason(s): WIC Staff Signature Date Breast Pump Release Form Single-User October 2025 1 SIGN SIGN

CIVIL RIGHTS IMPACT ANALYSIS A Civil Rights Impact Analysis is required before closing or relocating a local clinic site. This template needs to be provided to the State Office at least 60 days prior to closure or relocation. Additional pages may be included if needed. Local Agency/Clinic Name: Current Location New Location Address: 1. When will the move occur? 2. Distance from the old clinic to the new clinic? 3. Method and timing of notice to participants? 4. Will the clinic remain non-smoking? Provide assurance 5. Demographic assessment comparing old and new locations. Include available information. Demographic Map Racial composition of affected neighborhoods Census data 6. Is the new location in an area where at risk population or low-income housing are located? 7. Is the new location accessible for clients with disabilities? Is public transportation available? 8. Participation by Category: Women Infants Children Participation by race/ethnicity: White American Indian/Alaska Native Hispanic/Latino Asian Black/African American Native Hawaiian Pacific Islander Average participation for last six months Civil Rights Impact Analysis October 2025

CIVIL RIGHTS IMPACT ANALYSIS 9. Availability of other community resources including other local agencies 10. Consideration of Affirmative Action Plan Information The relative position of the area or special population served in the Affirmative Action Plan How much of the current need is met at each priority level and participant category? The potentially eligible individuals in the area 11. Public Notification What methods are being used (such as radio, phone calls, text messages, flyers, etc.)? 12. Cost effectiveness 13. Participant Access: Are there access issues for the new clinic location? Are there access issues for the availability of authorized vendors such as geographic barriers? State Agency Use Only Signature and Title of Reviewer: Date: Civil Rights Impact Analysis October 2025 SIGN

https://mdphhs.az1.qualtrics.com/jfe/form/SV_bdVRsYYQHv5N39Q

montanawicprogram@mt.gov

_____________________________________________________________________________ _____________________________________________________________________________ _____________________________________________________________________________ _____________________________________________________________________________ _____________________________________________________________________________ _____________________________________________________________________________ Continuing Education Credit (CEC) Approval Please submit immediately after completion of activity. You can submit an electronic version OR complete the form below. Today’s Date _______________ Staff Name _____________________ Position _______________ Agency Type of Education: Article Webinar Conference Other ___________________________________ Education Title Instructor(s) and Qualifications Number of WIC CECs Requested (1 hour of training = 1 CEC) Date(s) and Time(s) Attended Objectives: State objectives for each session/topic. Include concepts, ideas, or principles. Objectives must be measurable. For each CEC requested, list one item you learned and describe how you will apply this in your WIC job (attach additional pages as needed). Please attach program brochure/agenda and certificate. Return Completed Form to: Staff Approval Name:_______________________ Date approved:________________ # Credits approved:_____________ Continuing Education Credit Approval Form October 2025

____________ fo _____ End of Certification/Notice of Ineligibility The WIC certification for _____________________ will expire on r the following reason: (Name) (Date) _____ Your infant or child is due for re-certification- Please make your next appointment. _____ Your child is over five (5) years of age. _____ You are a non-breastfeeding woman more than 6 months postpartum. _____ You are a breastfeeding woman whose infant is over 1 year of age. _____ Your family’s income is too high. _____ You do not live in the Montana WIC Program service area. _____ You requested withdrawal from the WIC Program. _____ Program Fraud and/or Abuse: ______________________________________________ _____ Other: _________________________________________________________________ If your circumstances change and you would like to re-apply, please contact your local WIC office. For questions or information call: Participant/Guardian Signature Date WIC Staff Signature Date WIC Fair Hearing Procedures If you are dissatisfied with any decision about your eligibility for WIC, you are entitled to a fair hearing. 1. Submit a verbal or written request within 60 days of denial of participation to either your local WIC office or the State WIC office: WIC Program Director, PO Box 4210,1625 11th Ave., USFG Bldg., Helena, MT 59620-4210 (406) 444-5533. 2. You will then receive a copy of the Montana WIC Hearing Procedures. • You may be represented by an attorney or anyone at the hearing. • The hearing shall be within 3 weeks of receiving the request and shall be convenient for you. • You will have 10 days written notice of the time and place of the hearing. • The hearing will be conducted by an impartial official. • You have the right to present any evidence on your behalf. • You will be given the final decision in writing within 45 days from the date of the request for hearing. End of certification and Notice of Ineligibility October 2025 1 SIGN SIGN

USDA Nondiscrimination Statement

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/USDA-OASCR%20P-Complaint-Form-0508-0002­ 508-11-28-17Fax2Mail.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 End of certification and Notice of Ineligibility October 2025 2

eWIC Card Inventory Log

Date Card Stock Received from State Office (document first/last card #s) Card Stock Lost or Damaged (document first/last card #s) Card Mailed* (document HH# and Card #) Staff Name/# Reason*/Notes *eWIC cards must be mailed CERTIFIED. Please scan returned receipt into the participant chart for integrity and tracking purposes. Reason for mailing is required. eWIC Card Inventory Log October 2025

State Office Formula Order Form Ordering Clinic completes sections A, B and C. A. Clinic Information Local Agency: Ship to Clinic (if different): Requestor: Date: HH ID/Part ID: B. Product Information (include details such as calorie density, flavor, fiber, etc.) Specific Product Requested: New Request Subsequent Request State Number of Bottles/Tetra or Cans State Number of Bottles/Tetra or Cans Quantity for 1 mo: Quantity for 1 mo: If first month is a short month, then: Quantity for 2 mos: Quantity for add’l mo: Quantity for 3 mos: C. Documentation Completed/Verified Prescription has all required fields completed Signed by Person with Prescriptive Authority Documentation is in Manage Notes by appropriate staff that included their approval of the product and the reason for formula change D. State Office Only Accepted: Reviewed By: Order Date: Denied reason: Returned to complete? Review: The Montana State WIC office reserves the right to modify the formula order. Email to: MontanaWICProgram@mt.gov Formula Order Form October 2025

WIC Infant Formula Request Form All requests are subject to WIC staff approval. Sections A, B, C or D, and E must be completed for consideration. A. Participant Information: Name: DOB: Today’s Date: B. Length of Time Requested (circle one or fill in end date): Until end of certification Until first birthday Months of Age: ____________ Other Date: ______________________ C. Medical Formulas/Nutritional Products (Food Package 3): Prescribed Amount: □ Maximum Allowable OR ________________ per day Infant Formula Brief Product Description Diagnosis* Preterm □ Enfacare □ Neosure 22 calories per ounce; higher concentrations of proteins, vitamins and minerals (calcium and phosphorus) for catch up growth and development. □ Prematurity □ Low/Very Birth Weight □ Eosinophilic Esophagitis □ Failure to Thrive □ Malabsorption □ Milk Allergy □ Oral/Motor Feeding Issue or Developmental Delay □ Short Bowel Syndrome □ Soy Allergy □ Tube Feeding □ Other (specify): ___________________________ Hypoallergenic □ Alimentum □ Nutramigen Enflora LGG □ Pregestimil Appropriate for milk or soy allergy, malabsorption, and/or other gastrointestinal diseases. Hydrolyzed proteins and/or free amino acids; higher proportion of medium chain triglycerides (MCTs); gluten and lactose free. Hypoallergenic, Amino-Acid Based □ Alfamino □ Elecare □ Neocate □ PurAmino (contains soy oil) Appropriate for severe food allergies or multiple allergies, fat malabsorption, and/or other gastrointestinal diseases. Amino Acid based; higher proportion of medium chain triglycerides (MCTs); gluten and lactose free. Other Formula Requested ** *Weight gain, loss or maintenance does not qualify for WIC issued medical formula ** Standard formulas do not require a medical prescription for issuance. However, if a medical diagnosis is appropriate to justify no complimentary WIC foods issued from 6-12 months, then these may be deleted, and additional formula issued by checking the appropriate box below and indicating an appropriate diagnosis/justification above. D. Supplemental Infant Foods (required for 6-12 months old infants): □ NA - Provide Full Food Package, allow standard substitutions and tailoring □ Defer to Local WIC Registered Dietitian to determine appropriate supplemental foods □ Issue medical formula only (no foods) for 6-12 month-old infant □ Delete the following for 6-12 month-old infant (if nothing is circled, full food package will be issued): Cereal Fruits/Vegetables Meats Justification/other instructions: E. Healthcare Provider Information and Credential (all fields required): Phone: Name (Printed): Signature: Credentials: Formula Prescription Form October 2025

WIC Child/Adult Formula Request Form All requests are subject to WIC staff approval. All sections must be completed. A. Participant Information: Name: DOB: Today’s Date: B. Length of Time Requested: □ Until end of certification □ Other Date/Timeframe: C. Medical Formulas/Nutritional Products (Food Package 3): Prescribed Amount: □ Maximum Allowable OR ________________ ounces per day Pediatric Formula Brief Product Description Diagnosis* □ Pediasure (RTF)* □ Boost Kid Essentials (RTF)* □ Nutren Junior (RTF)* *Indicate fiber or 1.5cal in “other” section Lactose free, gluten free nutrition drink. Appropriate when a medical condition is present that requires enhanced nutrition support and/or tube feeding. □ Cerebral Palsy □ Cystic Fibrosis □ Eosinophilic Esophagitis □ Failure to Thrive □ Malabsorption □ Milk Allergy □ Oral Motor Feeding Issues □ Short Bowel Syndrome □ Soy Allergy □ Tube Feeding □ Other (specify): *Weight gain, loss or maintenance does not qualify for WIC issued medical formula. □ Kate Farms Pediatric Standard 1.2 □ Kate Farms Pediatric Peptide (circle) 1.0 OR 1.5 Free from 9 major allergens. Pea-based protein source. □ Compleat Pediatric (RTF) Food based liquid blend; corn and soy free; chicken-based protein source; appropriate for tube feeding. □ Nutramigen Toddler (Pwd.) Hypoallergenic complete formula appropriate for food allergies and/or malabsorption/GI disorders. □ Alfamino Junior (Pwd.) □ Elecare Junior (Pwd.) □ Neocate Splash (RTF) □ Neocate Junior (Pwd.) Hypoallergenic/amino acid-based formulas appropriate for food allergies and/or malabsorption/GI disorders. □ Peptamen Junior (RTF) □ Peptamen Junior HP (RTF) □ Pediasure Peptide (RTF) Lactose-free, gluten-free complete hydrolyzed, peptide based, formula appropriate for impaired GI function. Appropriate for oral or tube feeding. HP- high protein (16% of kcal), high calorie (1.2/ml) Adult Formula Brief Product Description □ Ensure (RTF) □ Boost Original (RTF) Gluten free, lactose-free. Complete formulas designed to enhance or supplement nutrition status when a medical condition is present. Other Formula Requested Medicaid providing formula Yes No D. Supplemental Foods: General Foods (REQUIRED): □ NA – Provide Full Food Package, allow standard substitutions and tailoring □ Defer to Local WIC Registered Dietitian to determine appropriate supplemental foods □ Delete the following from the food package (if nothing is circled, full food package will be issued): Cow milk Cheese Tofu Soymilk Yogurt Whole Grains Fruits/Vegetables Juice Peanut Butter Cereal Beans Fish Eggs Additional Foods- Must be Prescribed by Medical Provider □ Issue Whole Milk (children >2 and women) in addition to medical formula □ Substitute infant cereal for regular cereal □ Substitute infant fruits/vegetables for fresh, frozen and canned fruits/vegetables □ Substitute 18.75oz infant fruits/vegetables for juice Special Instructions: E. Healthcare Provider Information and Credential (all fields required): Phone: Name (Printed): Signature: Credentials: Formula Prescription Form October 2025

Formula Tracking Log Formula Tracking Log

October 2025

Date Formula Quantity Action (received, destroyed, issued) Associated Participant ID# Reason/Notes Staff Name/Signature

High-Risk Referrals October 2025 1 High-Risk Participant Referrals RD Registered Dietitian

LC Lactation Counselor/Lactation Consultant HCP Health Care Provider DNT Dental Services SS/MHP Social Services/Mental Health Care Provider * Only refer to LC if participant is breastfeeding ** Only refer if participant is not actively receiving prenatal care *** WIC RD to coordinate with outside RD, HCP or other specialist involved in the care of the participant Code DESCRIPTION RD LC* HCP DNT SS/MHP 101 UNDERWEIGHT WOMEN if pregnant or if postpartum after second consecutive measure. X 103 UNDERWEIGHT OR AT RISK FOR UNDERWEIGHT if infant refer on first measure; if child on second consecutive measure X X X 113 OBESE on second consecutive measure X X 114 OVERWEIGHT OR AT RISK OF BECOMING OVERWEIGHT if overweight on second consecutive measure X 121 SHORT STATURE OR AT RISK OF SHORT STATURE after second consecutive measure X 133 HIGH MATERNAL WEIGHT GAIN if pregnant X X 134 FAILURE-TO-THRIVE*** X X 135 SLOWED/FALTERING GROWTH PATTERN for two consecutive measures. X X X 141 LOW BIRTHWEIGHT AND VERY LOW BIRTHWEIGHT if infant with feeding difficulties or problems with weight gain X X X 142 PREMATURITY if breastfeeding infant X 201 LOW HEMATOCRIT/LOW HEMOGLOBIN if not at or above the established cut-off value upon recheck X X 301 HYPERMESIS GRAVIDARUM X

High-Risk Referrals

October 2025 2

Code DESCRIPTION RD LC* HCP DNT SS/MHP 302 GESTATIONAL DIABETES*** X 303 HISTORY OF GESTATIONAL DIABETES** X X 304 HISTORY OF PREECLAMPSIA** if pregnant X X 311 HISTORY OF PRETERM DELIVERY** if pregnant X X 312 HISTORY OF LOW BIRTH WEIGHT** if pregnant X X 331 PREGNANT AT A YOUNG AGE X 335 MULTIFETAL GESTATION if pregnant or breastfeeding X X 338 PREGNANT WOMAN CURRENTLY BREASTFEEDING if concerns about nutritional needs are present X X 341 NUTRIENT DEFICIENCY DISEASE*** X 342 GASTROINTESTINAL DISORDERS*** X 343 DIABETES MELLITUS*** X 344 THYROID DISORDERS*** X 345 HYPERTENSION AND PRE-HYPERTENSION*** X 346 RENAL DISEASE*** X 347 CANCER*** X 348 CENTRAL NERVOUS SYSTEM DISORDERS*** X 349 GENETIC AND CONGENITAL DISORDERS*** X 351 INBORN ERRORS OF METABOLISM*** X 352a ACUTE INFECTIOUS DISEASES*** X 352b CHRONIC INFECTIOUS DISEASES*** X 353 FOOD ALLERGIES*** X 354 CELIAC DISEASE*** X 356 HYPOGLYCEMIA*** X 358 EATING DISORDERS*** X X X X 360 OTHER MEDICAL CONDITIONS*** X

High-Risk Referrals

October 2025 3

Code DESCRIPTION RD LC* HCP DNT SS/MHP 362 DEVELOPMENTAL, SENSORY OR MOTOR DISABILITIES INTERFERING WITH THE ABILITY TO EAT*** X X X 381 ORAL HEALTH CONDITIONS (EXCEPT EARLY CHILDHOOD CARIES) if one or more food groups are being eliminated X X 382 FETAL ALCOHOL SYNDROME if feeding difficulties or problems with weight gain X X 383 NEONATAL ABSTINENCE SYNDROME X X 411 INAPPROPRIATE NUTRITION PRACTICES FOR INFANTS if routine diet is very low in calories and/or essential nutrients X X 425 INAPPROPRIATE NUTRITION PRACTICES FOR CHILDREN if routine diet is very low in calories and/or essential nutrients, pica X X 427 INAPPROPRIATE NUTRITION PRACTICES FOR WOMEN if consuming a diet very low in calories and/or essential nutrients, pica X X 602 BREASTFEEDING COMPLICATIONS OR POTENTIAL COMPLICATIONS FOR WOMEN X 603 BREASTFEEDING COMPLICATIONS OR POTENTIAL COMPLICATIONS FOR INFANT if infant shows signs of breastfeeding jaundice, weak or ineffective suck, inadequate weight gain X X 801 HOMELESSNESS X 901 RECIPIENT OF ABUSE X 902 WOMAN OR PRIMARY CAREGIVER WITH LIMITED ABILITY TO MAKE FEEDING DECISIONS AND/OR PREPARE FOOD X

Homeless Facility Statement Name of facility/institution: Address: Phone Number: Contact Person: I understand that the facility will not accrue financial gain or in-kind benefit from a person’s participation in the WIC program. I understand that foods provided by the WIC program may not be subsumed into a communal food service. The foods will be available exclusively to the WIC participant for whom they were issued. I understand that this facility will place no constraints on the ability of the participant to partake of the nutrition education and supplemental foods available under the WIC program. I understand that the intentional misuse of WIC foods by the facility may make me a party to fraud and may subject me to civil and criminal prosecution under State and Federal law. The homeless facility must notify the state/local agency if it ceases to meet any of the above conditions. This agreement must be renewed every two years. Contact Person’s Signature Date WIC Staff Signature Date This institution is an equal opportunity provider. Homeless Facility Statement October 2025 SIGN SIGN

m TRUSTEDMULTILINGUALCOMMUNICATION Point to your language Amharic Hebrew Portuguese Cf) G) 0) =:) CT) m C 0 v C\I Bosnian (Serbo Croatian) Bosanski Burmese Cambodian Cantonese Hatian Creole Krey61 Ayisyen Farsi French Fran ais French-Canadian fran ais canadien Hmong Hmoob Italian italiano Japanese Karen Kirundi lkirundi Korean Laotian Mandarin F.;ffl§li ೦DC Romanian Romana Russian Pycck1.111i1 Somali Soomaali Spanish Espanol Swahili Kiswahili Tagalog Tagalog Thai fl11f11VH.J Tigrinya G) German > Deutsch Nepali Urdu 0 Turkish Polish Vietnamese Tiirk e Polski Tieng Vift twitter.com/CTSlanguagelink facebook.com/ctslanguagelink Find usonline: ctslanguagelink Telephone: 1.800.208.2620 18riguagelink We speak your customer's language

Language Link WIC Guide October 2025 Language Link Interpretive Services WIC Program Guide Step 1: Call 1-888-338-7394 Step 2: Enter 5-digit Account Number: 29149# Step 3: Select Language from phone tree: Select 1 to be connected directly to a Spanish interpreter Select 2 to be connected directly to a Russian interpreter Select 3 to be connected directly to a Vietnamese interpreter Select 4 to be connected directly to a Somali interpreter, or Select 9 for all other languages If you require a 3rd party call, press 9 to reach a Customer Service Representative. May be needed if a speaker phone is not available or the individual is not in the office. No extra charge for 3rd party calls. Note: There is no need to confirm what dialect is needed before you call. You can simply state do not know language and customer service rep will determine which language is needed. If you know the dialect you can ask for it. Step 4: When prompted for employee ID number: 942123# Step 5: When prompted for division’s Program Number: 25# Attached is a poster you can use for non-English speakers to point to their primary language.

Reg Lead Agency Clinic Phone # Clinics Fax # Days/Hours 1 Beaverhead 683-4771 Dillion 683-3188 8-5:30 Wednesday, 8-12 Thursday 327 East Helena St Sheridan 3rd Mon 9-4 Dillon 59725 31 Big Horn 665-8726 Hardin 665-1025 Mon-Wed 8:30-5 200 N Mitchell Hardin 59034 25 Blackfeet 338-5311 Browning 338-4581 Mon-Fri 7-6 Old Person St #6 Browning 59417 35 Carter 775-6332 Ekalaka 755-6242 Mon- Thurs 9-5 106 E Park St. Ste 1229 Ekalaka 59324 3 Cascade 454-6950 Great Falls 453-3357 Mon-Fri 8-5 (Th 8:30-5:30) 115 4th St So 454-6953 Malmstrom Weds 8:45-4 Great Falls 59401 37 Chouteau 622-3771 Fort Benton 622-3411 First Tues & Weds of the month 8-5 1020 13th St Ft Benton 59442 26 Crow 679-2651 Crow 665-1025 Mondays and Tuesdays 9-4:30 10110 S, 7650 E Lodge Grass Wednesdays and Thursdays 9-4 Crow Agency 59034 32 Custer OneHealth 851-5050 Miles City 851-5002 Mon-Thurs 9-5 601 Main Street 851-5050 Ashland 3rd Tues quarterly Miles City, MT 851-5050 Forsyth 346-4242 2nd Tues monthly 9-4 59301 778-2824 Baker 778-2819 By appointment 851-5050 Broadus 3rd Thurs quarterly 851-5050 Hysham Last Tues quarterly 5 Dawson 377-5213 Glendive 377-2022 Thurs 8-5, M/T/W as needed 207 West Bell Wibaux quarterly by appointment Glendive 59330 Circle quarterly by appointment Terry quarterly by appointment Jordan quarterly by appointment 6 Deer Lodge 563-7863 Anaconda 563-2387 Tues and Thurs 8:30-4:30 118 E 7th Street, Suite Deer Lodge 2nd and 4th Tue 8:30-4:30 1E, Anaconda 59711 Drummond 1st Monday each month by appt Philipsburg 1st Monday each month by appt 7 Fergus 535-7488 Lewistown 535-2843 Wed-Fri 8-5 300 1st Ave North Harlowton 2nd Thurs 1-5 Lewistown 59457 8 Flathead 751-8170 Kalispell 751-8171 Mon 8-6, Tues-Fri 8-5 1035 1st Ave West Kalispell 59901 28 Fort Belknap 353-3157 Harlem 353-3282 Mon, Wed, Thur, Fri 8-5 656 Agency Main St 673-3777 Hays Tues 9-4 Harlem 59526 23 Fort Peck 768-2209 Poplar 768-5780 Mon & Thurs 8-4:30 107 H St E 653-5622 Wolf Point 653-1641 Tues & Wed 9-3:30 Poplar 59255 9 Gallatin 582-3115 Bozeman 582-3112 Mon-Fri 8-5 500 E Babcock 595-2309 Belgrade Thurs 8-5 WIC Local Agency Phone List

Bozeman 59715 539-7070 W. Yellowstone By appointment 539-7070 MSU WIC Clinic 2nd Thurs monthly 8-5 39 Glacier 873-2924 Cut Bank 873-2205 M-F 8-5 1210 E Main Cut Bank 59427 10 Hill 400-2421 Havre 265-6976 Mon-Fri 8-5 302 4th Ave Chester 2nd Tues (odd mos) 8-5 Havre 59501 357-2345 Chinook 4th Tues (even mos) 8-5 11 Lake 883-7307 Polson 883-7290 Mon- Thurs 8-5:30 802 Main St Ste B., Fri 8-12 Polson 59860 12 Lewis & Clark 457-8912 Helena 457-8990 Mon-Fri 8-5 1930 9th Ave, Broadwater 1st Monday each month 9-4 Helena 59601 White Sulphur July, October, January, April 10-3 13 Lincoln 283-6900 Libby 293-6622 M-F 8-5 320 E 2nd St 297-7220 Eureka Alternating Weds 10-4 Libby 59923 295-8318 Troy Alternating Mon 8-5 14 Missoula 258-4740 Missoula 258-4906 Mon-Fri 8-5 301 West Alder St Lolo 2nd Tues 9-3:30 Missoula 59802 Seeley Lake 1st Tues 10-3 Food Bank Mon & Thurs 8:30-5 24 Northern Cheyenne 477-4527 Northern Chey. 477-6330 Mon-Fri 8-4:30 100 Cheyenne Ave Lame Deer 59043 30 Park 223-1189 Livingston 219-0739 Mon- Fri 8-5 414 E Callender St Livingston 59047 38 Pondera 271-3247 Conrad 271-3248 Mon-Fri 8-5 311 S Virginia St Conrad 59452 15 Ravalli 375-6672 Hamilton 802-7185 Mon-Fri 8-5 205 Bedford Ste P Stevensville Wed 8:30-4:30 Hamilton 59840 Darby 3rd Weds of the month 9-3 18 Richland 433-2207 Sidney 433-6895 Tues & Wed 8-5 1201 West Holly St Sidney MT 59270 765-3473 Plentywood 765-3495 Twice a Month 9-5 22 Riverstone 247-3370 Riverstone 247-3340 Mon, Tue, Thur, Fri 8-5 Wed 9-6 123 S. 27th St. Red Lodge 4th Tues 10-3 Billings 59101 Joliet 4th Thur quarterly 9:30-3:30 Columbus 3rd Wed 10-3 Roundup 3rd Tues 10:00-3 Laurel 1st & 3rd Thur 9:30-4 Young Families 2nd Tue 8-3 29 Rocky Boy 395-1774 Rocky Boy 395-5731 Mon-Fri 8-4:30 6850 Upper Box Elder Box Elder 59521 Salish & Kootenai 745-3525 27 (CSKT) ext 5068 St. Ignatius 226-2772 Mon & Weds 8-5 Tues & Fri 8-12 880 Mission Drive Ronan Mon, Tues, Weds, Fri 8-5 St Ignatius 59865 Arlee Thurs 8-5 Hot Springs By appointment Elmo By appointment 17 Sanders 827-6931 Thompson Falls 827-6988 Mon-Fri 8-5 1111 Main St Rm 120, Noxon By appointment Thompson Falls 59873 Superior Thurs 8-5 Plains By appointment

Hot Springs By appointment 19 Silver Bow 497-5060 Butte 497-5095 Mon-Fri 8-5 25 West Front St Butte 59701 20 Teton 466-2562 Choteau 466-5292 Mon-Fri 8-5 905 4th ST NW Choteau 59422 36 Toole 424-5169 Shelby 424-2425 Mon-Fri 8-5 402 1st St S Shelby 59474 21 Valley 228-3626 Glasgow 228-3559 Wed & Fri by appt 621 Third St S Glasgow 59230 Malta Two Tues/month 9-4:30

Minimum WIC Food Stocking Requirements Refer to the Approved Food List for authorized brands/types. Montana authorized retailers must always have the following items in stock in the quantities specified below. Peer Groups 1 & 2 (Small & Medium-sized stores) Food Item Minimum Requirements Milk: Low-fat (1%) or Non-Fat (skim) 3 gallons total of any low-fat/non-fat type 3 half gallons total of any low-fat/non-fat type Whole milk 3 gallons 3 half gallons Cheese: 16-ounce packages OR 8-ounce packages 16-ounce packages 3 packages (16 ounces) of 2 varieties 8-ounce packages 6 packages (8 ounces) of 2 varieties Eggs Dozen only 3 dozen Breakfast Cereal: One of the cold or hot cereals must be WHOLE GRAIN 12-ounce or larger packages 6 boxes total (2 each of three varieties) 11-12-ounce hot cereal 2 boxes of one variety Whole Grains: Bread AND Rice Whole wheat and/or whole grain bread 3 loaves total of any authorized size bread 15-16 ounce packages brown rice and/or 14-16 ounce instant rice 3 packages of brown rice Bottled Juice 64-ounce bottles 3 bottles of 2 different flavors Peanut Butter 16-18-ounce jars 3 jars Legumes (mature beans): Bags of dried beans AND canned beans 16-ounce bags of dried beans 3 packages of 2 different varieties 15-16-ounce canned legumes/beans 10 cans total including two varieties Canned Fish: Light Tuna OR pink salmon 5-6-ounce cans 6 cans of light tuna 5-6-ounce cans 6 cans of pink salmon Fresh Fruits and Vegetables Fruits Two varieties in two different package types (fresh, frozen or canned) Vegetables Three varieties in two different package types (fresh, frozen, or canned) Infant Cereal: Two varieties

Minimum WIC Food Stocking Requirements 8-ounce box 2 boxes, any variety Infant Foods: Stage 2 fruits and vegetables and meats Fruit: 4-ounce jars of stage 2 10 jars, including 2 flavors Vegetables: 4-ounce jars of stage 2 10 jars, including 2 flavors Meat: 2.5-ounce jars 5 jars Infant Formula: Powdered formula in specific sizes Similac Advance: 12.4 ounce 6 cans Similac Soy Isomil: 12.4 ounce 4 cans Peer Groups 3 & 4 (Large stores & Supercenters) Food Item Minimum Requirements Milk: Low-Fat (1%) or Non-Fat (skim) 3 gallons total of any type 3 half gallons total of any type Whole milk 3 gallons 3 half gallons Cheese: 16-ounce packages OR 8-ounce packages 16-ounce packages 3 packages (16 ounces) of 2 flavor varieties 8-ounce packages 6 packages (8 ounces) of 2 flavor varieties Eggs Dozen only 3 dozen Breakfast Cereal: One of the cold or hot cereals must be WHOLE GRAIN 12-ounce or larger packages 6 boxes total (2 each of three varieties) 11-12-ounce hot cereal 2 boxes of one variety Whole Grains: Bread AND Rice Whole wheat and/or whole grain bread 3 loaves total of any authorized size bread 15-16-ounce packages brown rice and/or 14-16-ounce instant rice 3 packages of regular or quick/minute brown rice Bottled Juice 64-ounce bottles 3 bottles of 2 different flavors Peanut Butter

Minimum WIC Food Stocking Requirements 16-18-ounce jars 3 jars Legumes (mature beans): Bags of dried beans AND canned beans 16-ounce bags of dried beans 3 packages of 2 different varieties 15-16-ounce canned legumes/beans 10 cans total including two varieties Canned Fish: Light tuna OR pink salmon 5-6-ounce cans 6 cans of light tuna 5-6-ounce cans 6 cans of pink salmon Fresh Fruits and Vegetables Fruits Two varieties in two different package types (fresh, frozen or canned) Vegetables Three varieties in two different package types (fresh, frozen, or canned) Infant Cereal: Two varieties 8-ounce box 2 boxes of 2 different varieties Infant Foods: Stage 2 fruits and vegetables and meats Fruit: 4-ounce jars of stage 2 20 jars, including 2 flavors Vegetables: 4-ounce jars of stage 2 20 jars, including 2 flavors Meat: 2.5-ounce jars 10 jars Infant Formula: Powdered formula in specific sizes Similac Advance: 12.4 ounce 6 cans Similac Soy Isomil: 12.4 ounce 6 cans

Breastfeeding Peer Counselor Program Monitoring Form Agency/Clinics: Date of On-Site Monitoring Visit: Reviewer: BFPC Supervisor: BFPC(s): Annual Report Comments: Chart Review Area (Y= In Compliance/N= Out of Compliance/D= Discussion) HHID/WIC ID/Initials Infant DOB Cert. Start/End Dates Min. Contacts Made Y / N / D Y / N / D Y / N / D Y / N / D Y / N / D Documentation Y / N / D Y / N / D Y / N / D Y / N / D Y / N / D Scope of Practice Y / N / D Y / N / D Y / N / D Y / N / D Y / N / D Program Management (On-site Evaluation) BFPC program manager qualifications: Completed mandatory training? BFPC qualifications: Completed mandatory training? Describe system of referral from clinic to BFPC: Describe system of referral from BFP to lactation professional: Other Program Comments: Monitoring BFPCP Chart Review Form October 2025

Breastfeeding Peer Counselor Program Monitoring Form Pre-Monitoring Activities • Notification of monitoring in conjunction with general program review • Pull random charts for review (mother’s only) o 5 for small agencies o 10 for medium agencies o 15 for large agencies • Chart Review Areas o Contacts Reviewed • During pregnancy when possible • Every 2-3 days in the first 7-10 days post-partum • Weekly for the remainder of the 1st month • Monthly after the first month of infant’s life • Within 24 hours if problem is reported • Different frequency (mom’s request) or declination of contacts will be documented o Documentation • MIS Managed Notes (‘Breastfeeding’), and • Peer Counselor Contacts • Documentation within 5 business days by BFPC • Scope of Practice o If applicable, referred to breastfeeding expert when necessary o Practiced in the scope of ‘normal’ breastfeeding support • Pump Issuance (if applicable) o Review any documentation related to assessment and follow up Reference Nutrition Services Standards: https://wicworks.fns.usda.gov/wicworks/Topics/WICnutStand.pdf On-Site Review • Discuss program management questions with relevant staff • Observe BFPC contacts, referral process and workspace if possible • Discuss general monitoring topics during the Exit Interview Post-Monitoring Activities • Complete all documentation • Send comments, discussion topics and findings in report in conjunction with general program review • Corrective Action due within 30 days of report • Breastfeeding Coordinator to approve/respond with follow­ up Monitoring BFPCP Chart Review Form October 2025

Chart Review Areas Explained Review Area Expectation Caveats/Discussion Eligibility Pregnant women and migrant farmworkers must be notified of If appointment offered is Determination eligibility status within 10 days. All others must be notified not acceptable to the Timeline within 20 days. • When someone makes contact to request WIC benefits, they must be offered a certification appointment within this timeline. • A participant record will be queried (for past participation) or created and an appointment must be offered. Details of the initial contact and appointment offered must be documented in system. • Extensions on this timeline must be approved by the State office and documentation must be maintained. • This applies to all initial certifications and all other certifications if there has been more than a 2-month gap in certification timeframes. applicant, another appointment may be confirmed outside of the timelines, this is not a finding if documentation of this circumstance is clear. Participant Identification for all participants must be documented in system If scanned ID does not Identification and proof must be scanned in. match form selected in (ID) • Must be an approved form of ID. • Scanned proof must be legible. • Update ID if there is a significant change (i.e., name). • Alternative documentation when no proof exists (Montana WIC Affidavit). drop-down, it may be a simple human error (or may have been updated since certification) consider discussion. Authorized Each authorized representative must provide proof of identity May not have ID if alternate Representative the first time they attend an appointment. auth. rep has never come Identification • Must be an approved form of ID. • Scanned proof must be legible. • Update ID if there is a significant change (i.e. name). into the office. Since we do not have a signature for benefits, it may be hard to determine when they come in. Residence Each applicant must provide proof of residency. Participant may live in a Documentation • Must be an approved form of residency proof documented in the system. • Scanned proof must be legible. • Address at the time of certification must match the proof scanned in. • Physical address must be used (exception for participants on reservations which may be mailing address, PO Box, or self- attestation). • Alternate documentation when no proof exists (3rd party statement or Montana WIC Affidavit). neighboring state, justification must adhere to policy and verification that no dual participation exists. Updates to addresses may be made during a certification without proof scanned. Drop down proof should not be changed mid- certification unless proof is provided. Monitoring Chart Review Areas Explained October 2025

Chart Review Areas Explained Income/Adj. Income eligibility will be determined at each certification and Some discretion may be Eligibility documented accordingly. used in determining income Verification • Adjunctive eligibility (SNAP, Medicaid, TANF) will be verified and documented in system. o Electronic verification for all participants with associated IDs logged. • All income received by the household during the month (28-31 days) prior to the date of the application will be scanned and documented accurately. o Unless past 30 days income does not reflect current situation. • Tribal eligibility documented appropriately. • Montana WIC Affidavit, Zero Income, and/or Negative Income used and documented appropriately. o Signature should be the authorized or alternative representative listed in the chart. eligibility (i.e., newly unemployed, on maternity leave, working for cash intermittently). If questionable, research further. Verification of All participants who are transferring certifications from another Certification state must present a valid VOC, which will be documented and (VOC) scanned into the system. • At a minimum the document must have the name, date of certification and end of certification. • Staff will adhere to VOC policy in issuance of benefits which may require contact with sending state (verify benefits issued/redeemed if not known). If a participant is a migrant, or any participant that mentions they may be moving out of state, will be given a VOC. • Migrant workers will be given VOC at each appointment. • For other participants, their certification will only be terminated if move out of state is imminent, otherwise this will be done if/when move has been verified. Risk Code Every participant will be assigned all applicable risk codes At follow up appointments, if Assignment throughout a certification period. At least 1 risk code must be seen by paraprofessional always assigned for eligibility purposes. (aide) staff, updates to codes • If no risk exists, notice of ineligibility will be provided. • Certain risk codes require documentation for justification will not be documented unless it is system generated. • Breastfeeding dyads must be at the same priority level, Codes that require healthcare appropriate code shall be assigned if different. professional diagnosis will be • When a CPA- assigned code is resolved, documentation will appropriately assigned (CPA be made. clarifies diagnosis), but • At a minimum, a CPA will review risk codes at certification provider name/date or other and mid-certifications and update documentation if needed. details are not needed. Monitoring Chart Review Areas Explained October 2025

Chart Review Areas Explained Anthropometric and Hematological Measurements All measurements will be taken and followed up on according to policy. • Staff will attempt to gather data from another source if participant not physically present. These requests will be documented in the participant folder. • Information from a source other than WIC will be documented in the participant folder. Any exemptions will be documented. • Documentation of reviewing measurements with a participant/caregiver is required. • Remote certs and mid-certs require at least one attempt to follow-up for measurements after the appointment. The attempt must be documented in the participant folder. Food Package A CPA is responsible for assigning an appropriate food package (including all tailoring/changes to standard) for each participant. • Prescriptions for formula or nutritionals outside of standard will be reviewed for completeness and approved by the CPA. • An RD who has been deferred to for FPIII food assignments will assess and provide documentation in chart for food package decisions. • Any over or under issuance (without tailoring documentation) will be considered a finding. • All tailoring must have CPA documentation. • Signature for eWIC card is obtained for household. o The Alternative Means for Signature may be used and scanned into the participant folder. • Card replacement documentation in each household members’ chart. Monitoring Chart Review Areas Explained October 2025

Chart Review Areas Explained Nutrition and Breastfeeding Education At least 4 education contacts will be made per 1-year certification (about quarterly), and 2 education contacts per 6- month certification (about quarterly) will be made with each participant. • All standards must be applied (i.e., core/required topics covered at certification; accurate information; provided in an appropriate format, etc.). • Documentation of information provided must be clear (i.e., use of words such as “discussed” or “provided information on…”). • Education should align with benefit issuance (if benefits are provided more frequent than standard, education is expected). • Benefit Issuance in the setting of a missed nutrition education contact must be documented thoroughly. Nutrition Assessment Questions (NAQ) At each certification and mid-certification appropriate questions will be completed. • There will be a response to each question (may refer to an answer in another question). • Nutrition care plans are complete. • CPA assessment is thorough and appropriate. Goals A goal will be established with each participant at their certification appointment. • The goal will be Specific, Measurable, Attainable, Realistic and Timely (SMART) if possible (participant choice). • Follow up on the goal will be documented at subsequent appointment(s). • If participant declines setting a goal, documentation will made in chart. Ideally a new goal would be set with each appt. and follow up would continue throughout cert. period, however, if this is not happening, consider discussion. Participant Referral Referrals will be made at certification, and ongoing throughout the certification period as needed. • All mandatory referrals will be assessed and made (reference State Plan policy and High-Risk Table). • If no referral is appropriate, or is denied by participant, this must be documented. • Follow up is required on all referrals provided. • Additional referrals may be identified and made throughout certification period. Mandatory referrals missed (or not followed up on) will be considered for a finding. Monitoring Chart Review Areas Explained October 2025

Chart Review Areas Explained End of Every participant in a valid certification will be provided notice of If the participant fails to Certification the end of their certification at least 15 days prior to the end attend appointments as and Notice of date. scheduled, and they are Ineligibility terminated due to non- verbally (noted in chart). EOC date is printed on shopping • Notice may be in writing (scanned/logged in system) or participation, a notice is not list, however system does not log printing, so a note is required. needed. If the participant’s • Notice is generally provided at the last appointment of certification ends as the certification, but another method is acceptable if in expected, they only require mandatory timeframe. an EOC notice, not a NOI. Every participant must be provided a Notice of Ineligibility if: • They are determined to be ineligible during a certification Note: notice generated appointment. from system is same for • They are determined to be ineligible during a certification EOC and NOI and contains period due to changes in income or other criteria (i.e., information on Fair categorical change from breastfeeding to non- Hearings. This is the breastfeeding over 6 months). required notice for NOI, but EOC may be done informally and documented in chart. Monitoring Chart Review Areas Explained October 2025

WIC Chart Review Form Y= In Compliance (meets policy or regulation); N= Out of Compliance/Finding; D= Discussion Topic Agency: Date of On-Site Visit: Reviewer: Category P B N I C P B N I C P B N I C P B N I C HHID/Participant ID First & Last Initials Cert start/end dates Staff ID Number Remote Certification Y/N Midcert: Y/N Y/N Midcert: Y/N Y/N Midcert: Y/N Y/N Midcert: Y/N Chart Review Area Eligibility Determination Timeline Y / N / D Y / N / D Y / N / D Y / N / D Participant Identification Y / N / D Y / N / D Y / N / D Y / N / D Authorized Representative Identification Y / N / D Y / N / D Y / N / D Y / N / D Residence Documentation Y / N / D Y / N / D Y / N / D Y / N / D Income/Adjunctive Eligibility Verification Y / N / D Y / N / D Y / N / D Y / N / D Verification of Certification Y / N / D Y / N / D Y / N / D Y / N / D Risk Code Assignment Y / N / D Y / N / D Y / N / D Y / N / D Anthro./ Hgb. Measures Y / N / D Remote cert f/u: Y/ N / NA Y / N / D Remote cert f/u: Y/ N / NA Y / N / D Remote cert f/u: Y/ N / NA Y / N / D Remote cert f/u: Y/ N / NA Food Package Y / N / D Card Signature Y / N Y / N / D Card Signature Y / N Y / N / D Card Signature Y / N Y / N / D Card Signature Y / N Nutrition and Breastfeeding Education Y / N / D R/R signature: Y / N / Verbal Y / N / D R/R signature: Y / N / Verbal Y / N / D R/R signature: Y / N / Verbal Y / N / D R/R signature: Y / N / Verbal Nutrition Assessment Questions (NAQ) Y / N / D Y / N / D Y / N / D Y / N / D Goal Y / N / D Y / N / D Y / N / D Y / N / D Participant Referral Y / N / D Y / N / D Y / N / D Y / N / D End of Cert/ Notice of Ineligibility Y / N / D Y / N / D Y / N / D Y / N / D Monitoring Chart Review Form October 2025

WIC Financial Questionnaire Agency Name: _________________________________________________ Date of On-Site Monitoring Visit: __________________________________ Fiscal Months Reviewed: _________________________________________ Please Return to the State WIC Office by: ____________________________ Internal Controls: To the maximum extent possible, it is expected that the organization: • Separate responsibilities for receipt and custody of cash and other assets, maintaining accounting records on the assets; and authorizing transactions. • In the case of payroll activities, the organization, where possible, should separate the timekeeping, payroll preparation, payroll approval, and payment functions. Briefly describe the separation of responsibilities to provide an adequate system of checks and balances: Do the procedures for cash receipts and disbursements include the following safeguards? Yes No Receipts are promptly logged in, restrictively endorsed, and deposited in an insured bank account Bank statements are promptly reconciled to the accounting records and are reconciled by someone other than the individuals handling cash, disbursements and maintaining accounting records. All disbursements (except petty cash or Electronic Fund Transfer disbursements) are made by pre-numbered checks. Supporting documents (e.g. purchase orders, invoices, etc.) accompany checks submitted for signature and are marked “paid” or otherwise prominently noted after payments are made. Checks drawn to “cash” and advanced signing of checks are prohibited. Are multiple signatures required on checks? Comments:

WIC Financial Questionnaire ACCOUNTING: Does the organization have written accounting policies and procedures to ensure uniform practice in the following areas (check boxes below for each): Written Policies and Procedures (documents may be requested) Yes No Procurement Contract Administration Payroll Timekeeping Inventory Vendor Payments Federal Draws Grants Budgeting and Accounting Cash Management Maintenance of Effort Allowable Costs Indirect Costs Audit Resolution Records Retention 1. Are all appropriate accounting staff trained on, and have access to current policies, procedures, and instructions on accounting for and expending WIC funds? 2. What software does the organization use to record accounting transactions (i.e. QuickBooks, Visual Bookkeeper, Socrates Media, Peachtree, or other method or custom Proprietary System)? a. How is WIC funding identified and tracked in the accounting system apart from other funding streams and expenditures? b. Are all sources of funds identified and tracked in the accounting system? 3. Does the entity use of Chart of Accounts and Accounting Manual? If so, please provide a list of Chart of Accounts utilized by the program. 4. For the WIC Contract, does the accounting system provide information on the following: Authorizations Obligations

WIC Financial Questionnaire Funds Received Program Income Subcontracts Outlays Unobligated Balances 5. Are obligations recorded by: Yes No Funding Sources Object Code 6. Is there a system to compare actual vs. budgeted expenditures? CASH MANAGEMENT: Yes No 1. Are all cash receipts deposited daily? a. If no, how are they deposited? b. Are all deposits intact? 2. Is the cash receipts function performed by someone other than the person who is responsible for signing checks, reconciling bank accounts or maintaining noncash accounting records, such as accounts receivable, the general ledger, or the general journal? a. Who performs the cash receipts function? (name & title) b. Who signs the checks (name & title)? c. Who maintains the accounts receivable, the general ledger, and the general journal (name & title)? 3. Does the organization have policies and procedures to ensure that the time elapsing between the transfer of funds and the disbursement of those funds is minimized? 4. Are bank statements received directly, unopened by the person who prepares the bank reconciliation? 5. Are bank statements reconciled at least monthly? a. Who reconciles the bank statements (name & title)? 6. Are paid checks examined for date, name cancellation, and endorsements at the time the reconciliation is prepared?

WIC Financial Questionnaire 7. Are vouchers or supporting documents identified by funding source, number, date and expense classifications? 8. Do supporting documents accompany checks when they are submitted for signature? 9. Are invoices or vouchers approved in advance by authorized officials? 10. Are blank checks secured? Comments: EXPENSES: 1. How are WIC expenses tracked? Reconciled? 2. Explain the process of how the WIC budget is prepared and monitored. 3. Explain any other funds used to supplement WIC funding and how expenses are tracked and delineated from WIC funds. Please include funding sources other than WIC used for staff salaries, benefits, etc. INDIRECT COSTS: Yes No 1. Is there a current federally approved indirect cost rate? 2. What is the rate: 3. What is the effective date? TIME RECORDS: Yes No 1. Does the timesheet allow reporting for more than one program? 2. Are timesheets being used appropriately? 3. Are basic work records of the employees signed, approved, and maintained? 4. Are all agency personnel keeping time records? 5. Do time studies accurately reflect the time sheets? Comments:

On-Site Observation: Clinic Review Area Expectation Results Y= In compliance N= Out of compliance/Finding D= Discussion Clinic • Clean, safe, and well-maintained Environment • Equipment (anthro./hgb.) is clean/well-maintained and has been checked on schedule for accuracy • Verify equipment inventory • Easy to find (good signage) Eligibility • Review clinic process and interview staff for how they Determination document initial certifications (or certs with >2 mo. Timeline lapse) with use of initial contact button. Must create record at time of inquiry for appointment and document first appt. offered (not necessarily completed) Required • “We Accept WIC Benefits” decal Information • Hours of Operation Posted • List of stores that accept WIC benefits locally • Non-smoking facility designation • Current income eligibility guidelines (IEGs) • Language Translation “Point 2 Your Language” • MOU Disclaimer Civil Rights & • Current “And Justice for All” posted wherever eligibility Accessibility is being determined and benefits are issued • Current “Fair Hearings” posted wherever eligibility is being determined and wherever benefits are issued • Non-Discrimination statement being used appropriately (outreach materials, anything discussing eligibility, etc.) • Clinic is compliant with ADA standards • Access to language translation (LEP compliance) • Civil Rights complaint process understood • Racial/Ethnic data collection (observe question asked or interview staff) Integrity & • Employee may not act as a proxy for participant Confidentiality • Employee must not have a conflict of interest (may not serve relative/friend in clinic) • Confidentiality maintained (participant information kept out of site, only shared when appropriate and according to policy) • Separation of duties (when possible- division between staff who do income and risk code eligibility) • Homeless facility Statement Monitoring On-Site Observation: Clinic October 2025

On-Site Observation: Clinic Nutrition • Information available (posters, brochures, etc.) must be Education up to date and appropriate for population Materials • Materials are distributed appropriately, primarily to reinforce interactive education • Have substance abuse forms available- staff know how/when to use it Breastfeeding Promotion & Support • Breastfeeding Coordinator providing training, outreach, and support for clinic • Clinic is breastfeeding friendly Security • eWIC cards (locked) • Pumps (locked) • Formula Storage (out of sight, secure location) • Check disaster and security plan Outreach, • Progress on current outreach plan Retention & • Clinic is pulling list of eligible participants without Participation issuance monthly to follow up/schedule • Clinic efforts to improve retention (appointment scheduling, clinic hours/availability, access) Self-Monitoring • If Tier 1 in the last review- verify that self-monitoring completed using State process • Review results/changes clinic made as a result Quality Comments • Note anything you observe or hear about that deserves recognition and praise (non-scored) • Note anything related to assessment of staff in local agency roles (Nutrition Coordinator, Breastfeeding Coordinator, and Local Agency Resource Coordinator (LARC)) • Local policies are posted, if applicable (best practice) Monitoring On-Site Observation: Clinic October 2025

On-Site Observation: Appointments (If BFPC or FMNP services are observed, document on those monitoring forms) WIC Participant ID Number/HH Number WIC Category P N B C I P N B C I P N B C I Appointment Type Staff Observed Eligibility Determination Timeline • Documenting initial contact date and first appointment offered for all new participants (initial certs) and returning with >2-month gap in certification Certification Procedures • Income, ID, Residence checked & scanned • Missed appointments (pregnant/migrant) follow-up Voter Registration Procedures • Forms available • Registration offered at all certification appointments and when address has changed • Disclaimer signed and scanned Anthropometrics/Bloodwork • Proper technique used • On schedule • Discussed with participant/caretaker Food Package/Redemption • Food list reviewed • Food package reviewed (including sub options/tailoring) • Redemption process reviewed • Informed of resources for balance/food list inquiries Required Topics (cert. and as needed only) • Purpose and benefits of program • Substance Abuse screening/form provided • Breastfeeding (pregnant/breastfeeding women) • Rights & Responsibilities (read, signed) Nutrition Education/VENA • Education provided during appointment • Participant-centered • Appropriate topic/Up-to-date information • Using OARS/MI style Monitoring On-Site Observation: Appointments October 2025

Pre-Visit Worksheet State Staff Sign-Off Role Staff Name & Signed Initials Date Financial Specialist Vendor Services Integrity Breastfeeding Coordinator Civil Rights Nutrition Coordinator Outreach Coordinator Information Technology (IT) Specialist State Director Agency Name: Date of On-site Visit: Monitoring Staff: Grants Received (separate forms for monitoring must be completed): FMNP BFPCP Participation (most recent funding formula): Agency Size: Small Medium Large Lead Local Agency Information Address (physical): Agency Director: Main Clinic Days Open: Hours: Staff (list all names and roles): Satellite Clinics (If applicable) Location/address: Days Open: Office Hours: Staff (list all names and roles): Results from Previous Monitoring (attach score sheet and CAP) Date of Last Monitoring: Tier: 1 2 3 Tier 2/3: Are self-chart reviews submitted on time? Y N Tier 3: CAP Completion Verification Submitted? Y N Comments: Pre-Visit Finding Areas:______________________________________________________________________________ Pre-Visit Discussion Areas____________________________________________________________________________ Monitoring Pre-Visit Worksheet October 2025

Pre-Visit Worksheet Contract/Fiscal Compliance (Financial Specialist) Contracts Yes No Comments Are current signed satellite or sub-contracts on file and submitted in a timely manner? Are Services Contracts or Task Orders Submitted on time? Expenditure Reports Reviewed (list month(s)/year(s)): Expenditure Report Review Yes No Comments Has all back-up documentation been received? Are expenditure reports submitted on time in accordance with executed contract? Are expenditure reports accurate? Do the payroll documents confirm the amounts listed in the expenditure reports? Is there any line item that is not accounted for with appropriate documentation? Are expenses accounted for in the correct fiscal year? Were there capital expenditures? Was it pre- approved by FNS? Were all expenses reasonable, necessary and actual to the MT WIC program? WIC Financial Questionnaire Received (date): Complete: Y N Comments: Finding: Discussion Topic: Timestudy (Financial Specialist) Are local agency staff submitting on time? Y N Comments: Finding: Discussion Topic: Monitoring Pre-Visit Worksheet October 2025

_________________________________________________________________________________________ _________________________________________________________________________________________ _________________________________________________________________________________________ Pre-Visit Worksheet Integrity Separation of Duties (SOD) Is the Local Agency in compliance with SOD policy? Y N Have there been any concerns related to SOD audits since the last monitoring? Y N Comments: _ Over-issuance Has this Local Agency had any instances of over-issuance during this period? Y N Was the Agency required to repay the State Office? Y N Received within 30 days: Y N Comments: _ Finding: Discussion Topic: Local Agency Clinic Roles- Assessment Nutrition Coordinator: Comments: _______________________________________________________________________________ Breastfeeding Coordinator: Comments: _______________________________________________________________________________ Local Agency Retail Coordinator: Comments: _______________________________________________________________________________ Finding: Discussion Topic: State Office Compliance Checks (Nutrition Services) Has the local agency shown improvements in state-office compliance checks over the past 2 years? Y N N/A Comments: ___________________________________________________________________________ Finding: Discussion Topic: Monitoring Pre-Visit Worksheet October 2025

Pre-Visit Worksheet Training (Nutrition Coordinator) Staffing Ratio: Participant #’s: ____ Full Time Staff (> 20hrs/wk.): ____ Part Time Staff (<20 hrs./wk.): ____ Staff Roles: CPAs_____ Aides _____ Other _____ Ratio: (FTE/Participation #s): _____ Staff Training Form completed and submitted within 60 days for all new staff: Y N New Employee Training completed for all new staff within 12 months: Y N Continuing Education Credits completed by all staff annually: Y N Annual Civil Rights Training completed: Y N Comments:___________________________________________________________________________ Finding: Discussion Topic: Complaints (Vendor Coordinator/Integrity) Has the local agency received any program complaints since the last monitoring visit? Select one: Retailer Complaints Participant Complaints No complaints No Were there any occurrence(s) of the local agency not responding/following up on complaints received since the last monitoring visit? Yes If there were occurrences of a participant committing the same type of WIC program violation, did the local agency provide the appropriate response? Yes No Has the State Office received any complaints about the Local Agency since the last monitoring? Yes (If yes, how many: ) No Comments:

Finding: Discussion Topic: Nutrition/Breastfeeding- (Nutrition and Breastfeeding Coordinators) Is the annual Nutrition and Breastfeeding Education Plan completed and submitted on time: Y N Is the Plan appropriate to the Local Agency assessed needs and aligned with State goals and objectives? Y N Comments: Finding: Discussion Topic: Monitoring Pre-Visit Worksheet October 2025

Pre-Visit Worksheet Breast Pump Inventory (Breastfeeding Coordinator) Pump Log received on time: Yes No Are the Breast Pump Log and MIS inventory being used according to policy? Y N Is the documentation of assessment for pump issuance according to policy? Y N Is there a 3 day follow-up once a pump is issued? Y N *Review at least 3 charts from pump log HHID/Participant ID Comments Comments: _ Finding: Discussion Topic: Outreach (Outreach Coordinator) Participation % change (increase vs. decrease since last monitoring): Outreach Plan/Log Reviewed: Yes No Outreach Plan Approved (including yearly newspaper published): Yes No Outreach to target population met: Yes No Local Agency Website reviewed: Yes No Comments: _ Finding: Discussion Topic: Information Technology- IT Specialist Network: Off On IT equipment survey was returned, and inventory was updated: Yes No Comments:

Finding: Discussion Topic: Monitoring Pre-Visit Worksheet October 2025

Pre-Visit Worksheet Civil Rights Log: Monitoring Lead Civil Rights Log received on time: Yes No Civil Rights Log reviewed: Comments: _ Finding: Discussion Topic: eWIC Card Log: Monitoring Lead eWIC Card Log received on time: Yes No eWIC Card Log reviewed: *Review at least 3 charts from log HHID/Participant ID Comments Comments: _ Finding: Discussion Topic: Formula Log: Monitoring Lead Formula Log received on time: Yes No Formula Log reviewed: *Review at least 3 charts from log HHID/Participant ID Comments Comments: _ Finding: Discussion Topic: Monitoring Pre-Visit Worksheet October 2025

WIC Local Agency Monitoring Process Monitoring Process October 2025 Overview The Montana WIC State Office will complete a comprehensive monitoring evaluation for each contracted agency on a biennial basis. This document outlines the components of the general program monitoring process, timelines for each activity, and reference to associated materials. In addition to ensuring program compliance, our goal is also to support local agencies through technical assistance and recognize areas of best practice and exceptional work. Additional program reviews for Farmers Market Nutrition Program (FMNP) and the Breastfeeding Peer Counselor Program (BFPCP) will be conducted during the same time as the regular program reviews. Separate forms for process and documentation will be used and referenced. Communication All monitoring activities will be communicated in the following way: • Written material will be mailed certified to the contract liaison identified during the contracting process for the current federal fiscal year. • A copy of materials will be emailed to the WIC Director and agency Health Officer (or equivalent position) identified during the contracting process of the current federal fiscal year. • It is expected that the individuals receiving the communication will share relevant information with interested parties which may include, but are not limited to, agency staff and contract signers. • The dates of correspondence will be documented based on the signed receipts of certified mail, and/or email read receipt, and will start each timeline in the corresponding process. o If certified mail receipt is not received, follow-up will take place with the intended recipient to verify notification was received or needs to be re-sent. o This documentation will be maintained in the electronic monitoring file at the State Office. Scheduling By July 31st of each year, State agency staff will determine the list of agencies to be monitored, and tentative schedule of site visit for the upcoming fiscal year. A clinic services staff member will be assigned to each agency and will then be responsible on following through all monitoring activities, beginning with confirmation and notification of the on-site visit with local agency leadership staff.

WIC Local Agency Monitoring Process Monitoring Process October 2025 Initial Notification Packet A packet of information will be sent to the agency contacts at least 60 days prior to the on-site monitoring visit. Several items will be due back to the State Office for review, these items must be received no later than 30 days prior to the on-site visit. This packet will include: • An official notification letter specifying the details of the visit, including date(s) of visit, times of entrance and exit, months of interest for financial review, and information about associated materials included. The notification will also include if a BFPCP and/or FMNP review will be completed in conjunction with general monitoring. • Monitoring Process document • A flowsheet showing the overall monitoring process at a glance, including timelines for each activity. • The Financial Questionnaire and copies of expenditure reports for the months being reviewed. • Inventory list for local agency verification Pre-Monitoring Activities The State WIC staff completes the following activities prior to the visit on-site. Pre-Monitoring Worksheet: The State WIC staff complete an internal pre-visit worksheet to review local agency program areas that cannot be evaluated in the chart review or on-site during observation. This worksheet includes a review of the following: • Agency information and structure • Review of last monitoring • Contract/Fiscal compliance • Time study • Integrity: Separation of duties, over issuance of WIC foods, card replacements • Local agency clinic roles • Training • Complaints • State office compliance checks • Nutrition/Breastfeeding • Breast pump inventory • Outreach • Information technology For each of the areas identified in the pre-visit worksheet, State Office staff will determine if a finding is warranted, or if it is a discussion item, based on severity of the issues and if trends are identified.

WIC Local Agency Monitoring Process Monitoring Process October 2025 Chart Reviews: State WIC staff will review WIC participant charts for compliance prior to the on-site visit. The finding areas reviewed are clearly outlined in the Chart Review Form and the Chart Review Areas Explained Form. These finding areas are set for each two-year review cycle, however, they may change over time to best ensure regulatory and policy compliance as well as program quality and integrity. The size of the agency, based on participation identified in the current contract funding formula, will determine how many charts to review: • Small Clinics (0-400 Participants): 10 Charts o 4 children, 2 pregnant women, 1 breastfeeding mother and her infant, 1 non- breastfeeding mother and her infant o Agencies with less than 100 participants based on the current funding formula will have 10% (rounded up to the nearest whole number) of participant charts reviewed. A variety of participant categories will be selected. • Medium Clinics (401-800 Participants): 15 Charts o 4 children, 3 pregnant women, 2 breastfeeding mothers and their infants, 2 non- breastfeeding mothers and their infants • Large Clinics (>801 Participants): 20 Charts o 4 children, 4 pregnant women, 3 breastfeeding mothers and their infants, 3 non- breastfeeding mothers and their infants Note: If a chart pulled for a mother-infant dyad can only be reviewed for one of the members (i.e., foster care situation), the State staff may select another chart at their discretion to make up the total number of charts to be reviewed. The State staff has the discretion to change ratios of the chart to review. *Agencies with more than 3 independently operating clinics will have 4 charts reviewed from each of the clinics (1 mother-infant dyad, 1 child, and 1 pregnant woman) Charts to be reviewed will be obtained from a random data pull and will be selected based on the following criteria: • Verified to have been certified (including VOC) and served within relevant local agency • Include at least 2 visits, preferably more (i.e., at least certification, follow-up and mid- certification is ideal) • At least one “high-risk” chart based on nutrition risk criteria and/or food package III designation The chart review period may include any timeframe since the last monitoring evaluation, however, only one certification period will be considered, and this will be clearly identified in the report.

WIC Local Agency Monitoring Process Monitoring Process October 2025 FMNP and/or BFPCP Review If the local agency receives funds for, and administers, one of these programs, they will also be monitored in conjunction with general program monitoring. Each of the programs has a separate form for pre-visit activities, chart review, and on-site observation. • Pre-visit activities, including chart reviews, will be completed by the FMNP coordinator and/or the breastfeeding coordinator accordingly • Some aspects of monitoring for those programs will cross reference with general monitoring (i.e., financial integrity and processes, staff training, program management, complaints, and civil rights) • The final report will incorporate findings from all reviews completed • Corrective Action Plans will be completed and submitted using the same forms for the regular monitoring, and on the same timeline • If an agency is Tier 3 in regular monitoring, but has no (or minimal) findings in BFPCP or FMNP monitoring, the State Agency may opt to not review these programs during the additional monitoring evaluation that will take place the following year On-Site Review The purpose of an on-site visit is to confirm and witness that programmatic activities are taking place according to regulation and policy, as well as to confirm that what is being documented in charts is what is happening in the clinic. Additionally, this is an opportunity for state and local staff to share information and answer questions about the clinic operations and monitoring process. The following activities will take place on-site: • Entrance Interview- this will occur at the beginning of the first day to introduce staff and review the expectations of the visit. This is a very brief meeting intended for staff who will be directly participating in the clinic review. • Observation- the State staff will observe clinic appointments, processes, and environment. The areas observed and corresponding expectations are clearly identified in the observation forms. o If an appointment or activity is not available for observation, there will be interviews with staff to describe the process that would have been observed • Exit Interview- at the conclusion of the monitoring visit, State staff will conduct an exit interview recapping the preliminary findings from the monitoring evaluation. Final score and findings will not be known at this time. All pertinent WIC and management staff should plan on attending the exit interview. This will be a more formal discussion of the monitoring process and status.

WIC Local Agency Monitoring Process Monitoring Process October 2025 Follow-up Procedures After on-site review, staff will compile the results of the monitoring and document this information in a monitoring report. The report, along with associated cover letter, scoring sheet, and (if applicable) FMNP and/or BFPCP forms will be sent to the agency within 30 days of the on-site visit. The local agency is welcome to review the report and consult with the State Office on any findings or questions that arise. A corrective action plan (CAP)* addressing the finding areas identified in the monitoring report will be submitted to the State Office within 30 days of receipt of the monitoring report. Charts with eligibility errors must be fixed as part of the CAP submission. A letter will be sent to the local agency indicating acceptance or denial of the CAP within 30 days of receipt. If the CAP is denied, the local agency will be given an additional 15 days to update and re-submit their CAP. Documentation of completed activities will be submitted to the State Office within 60 days. *Note: The CAP is developed by the local agency and should incorporate specific activities to address each finding area to avoid deficiencies going forward. The State Office will provide a template. The local agency can choose to use it or create their own. Scores and Tiers The State Office will use an objective method to determine the “tier” a local agency falls into, which will ultimately determine follow-up activities. Scoring (BFPCP and FMNP are not scored): • Each chart, observation and pre-visit finding area will be assigned a point value • Findings will be entered into scoring spreadsheet with pre-set calculations to determine a percent “compliance” • Staff will look for trends to determine whether an issue is a finding or not, which will include the following criteria: o More than 1 issue in an identified chart review area for small agencies o More than 2 issues in an identified chart review area for medium agencies o More than 3 issues in an identified chart review area for large agencies • Issues identified but not considered “trends” will be listed in the discussion section of the monitoring report rather than scored, and will not require a CAP. • An additional factor in the scoring sheet will include a calculation related to how many areas have findings in them. The purpose of this is to account for the range of non­ compliance in the overall monitoring process. • Observation and pre-visit review areas are also assigned a point value which will be calculated if a finding is assessed. Tier 1 (≥80%) follow-up: Self-monitoring is required to be completed at the local level using State forms for chart review and observation the following year. The local agency will request the charts from the State Office to be used in this review. Any issues found during this review will be addressed within 60 days of the review. Results of this monitoring will be maintained on file and reviewed at the next State on-site monitoring visit.

WIC Local Agency Monitoring Process Monitoring Process October 2025 Tier 2 (65-79%) follow-up: Six months after the monitoring report is received, the local agency will complete self-chart reviews on 10 charts*. A meeting will be set up with State Office staff to review the self-chart audit. If, after the 6-month self-review, the state agency has not seen significant improvement, they may assign 9-month and/or 12-month additional self-chart reviews. The additional chart reviews may consist of less than 10 charts at the discretion of the state office staff. There will be at least one chart per category*. All documentation from the review(s) will be submitted to the State Office (including observation forms). Tier 3 (<65%) follow-up: Self-chart reviews are required on 10 charts* at 6 and 9 months after the monitoring report is received. All documentation from the reviews will be submitted to the State Office (including observation forms). A meeting will be set up with State Office staff to review each self-chart audit. An additional full monitoring evaluation will be completed one year after the initial visit (agency will continue to remain on cycle for future monitoring). *Local agencies with less than 100 participants will have 10% of charts reviewed at the 6- month review. Scoring Example for Small Agency (<400 participants): • Files: Number of charts reviewed by State Office. • Occurrences: Number of finding(s) in review area. In example below, 4 occurrences in Risk Code Assignment means 4 charts of the 10 reviewed were noncompliant in this area. • Weight: Maximum number of points possible assigned to each review area. 264 (points earned) / 300 (maximum points) = .88 or 88% (Score)

Negative Income Statement I____________________________________ declare that I have negative income (invested income that produced a loss) and have presented WIC staff with supporting documentation. I attest that if I knowingly falsify information in order to receive benefits, I am subject to disqualification from the Montana WIC Program. Participant’s Signature Date WIC Staff Signature Date INSTRUCTIONS: Scan into participant folder along with supporting documentation. USDA Nondiscrimination Statement 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/USDA-OASCR%20P-Complaint-Form­ 0508-0002-508-11-28-17Fax2Mail.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. Negative Income Statement October 2025 SIGN SIGN

Nutrition Risk Codes The following nutrition risk codes require a diagnosis by a qualified healthcare provider (HCP) with prescriptive authority in the State of Montana. Participant may self-report HCP diagnosis. 134 Failure to Thrive 151 Small for Gestational Age 153 Large for Gestational Age 301 Hyperemesis Gravidarum 302 Gestational Diabetes 303 History of Gestational Diabetes 304 History of Preeclampsia 321 History of Spontaneous Abortion, Fetal or Neonatal Loss 337 History of Birth of a LGA infant 336 Fetal Growth Restriction 339 History of Birth with Nutrition Related Congenital or Birth Defect 341 Nutrient Deficiency or Diseases 342 Gastrointestinal Disorders 343 Diabetes Mellitus 344 Thyroid Disorders 345 Hypertension and Pre-Hypertension * Computer generated code. ° Both CPA and computer-generated code. ### Referral may be required for High-Risk code. 346 Renal Disease 347 Cancer 348 Central Nervous System Disorders 349 Genetic and Congenital Disorders 351 Inborn Errors of Metabolism 352a Infectious Diseases – Acute 352b Infectious Disease - Chronic 353 Food Allergies 354 Celiac Disease 355 Lactose Intolerance 356 Hypoglycemia 358 Eating Disorders 360 Other Medical Conditions 361 Mental Illness 363 Pre-Diabetes 381 Oral Health Conditions 382 Fetal Alcohol Syndrome 383 Neonatal Abstinence Syndrome Category/Priority Code Description P B N I C 1 1 6 101* UNDERWEIGHT WOMEN Pregnant Women: Pre-pregnancy BMI < 18.5. Non-Breastfeeding Women: Pre-pregnancy or Current BMI < 18.5. Breastfeeding Women who are < 6 months Postpartum: Pre-pregnancy or Current BMI < 18.5. Breastfeeding Women who are ≥ 6 months Postpartum: Current BMI < 18.5. Nutrition Risk Code Table October 2025

Nutrition Risk Codes Category/Priority Code Description P B N I C 1 3 103* UNDERWEIGHT OR AT RISK OF UNDERWEIGHT –INFANTS AND CHILDREN Underweight ≤ 2.3rd percentile weight-for-length for infants or children birth to <24 months as plotted on the CDC birth to 24 months gender specific growth charts. ≤ 5th percentile BMI-for-age for children age 2-5 years as plotted on the 2000 CDC age/gender specific growth charts. Risk of Underweight > 2.3rd percentile and ≤ 5th percentile weight-for-length birth to <24 months as plotted on the CDC birth to 24 months gender specific growth charts. > 5th percentile and ≤ 10th percentile BMI-for-age for children age 2-5 years as plotted on the 2000 CDC age/gender specific growth charts. 1 1 6 111* OVERWEIGHT WOMEN Pregnant Women: Pre-pregnancy BMI ≥ 25.0. Non-Breastfeeding Women: Pre-pregnancy BMI ≥ 25.0. Breastfeeding Women who are < 6 months Postpartum: Pre-pregnancy BMI ≥ 25.0. Breastfeeding Women who are ≥ 6 months Postpartum: Current BMI ≥25.0. 3 113* OBESE (CHILDREN 2 – 5 YEARS) A child age 2-5 years whose BMI or weight-for-stature is ≥ 95th percentile as plotted on the 2000 CDC 2 - 20 years gender specific growth charts. Nutrition Risk Code Table October 2025

Nutrition Risk Codes Category/Priority Code Description P B N I C 1 3 114° OVERWEIGHT OR AT RISK OF OVERWEIGHT (INFANTS AND CHILDREN) Overweight ≥ 85th and < 95th percentile for BMI-for-age or weight-for-stature for children aged 2- 5 years as plotted on the 2000 CDC 2 – 20 years gender specific growth charts. Risk of Overweight Biological mother with a BMI of ≥ 30 at time of conception or at any point in the first trimester of pregnancy for an infant less <12 months*. Biological mother with a BMI of ≥ 30 at the time of certification for a child age 1 year and older. (If the mother is pregnant or ≤ 6 months post-partum use her pre- pregnancy weight to assess). * Biological father with a BMI ≥ 30 at the time of certification for birth to 5 years. * * BMI must be based on self-reported weight and height by the parent in attendance. One parent may not “self-report” for the other parent. Weight and height measurements may also be taken by staff at the time of certification. 1 3 115* HIGH WEIGHT- FOR- LENGTH (INFANTS AND CHILDREN < 24 Mo. OF AGE) ≥97.7th percentile weight-for-length for children < 24 months of age as plotted on the CDC birth to 24 months gender specific growth charts. 1 3 121* SHORT STATURE OR AT RISK OF SHORT STATURE (INFANTS AND CHILDREN) Short Stature: ≤ 2.3rd percentile length-for-age for birth to < 24 months as plotted on the CDC birth to 24 months gender specific growth charts. ≤ 5th percentile stature-for-age for children age 2-5 years as plotted on the 2000 CDC age/gender specific growth charts. At Risk of Short Stature: > 2.3rd percentile and ≤ 5th percentile length for-age for birth to <24 months as plotted on the CDC birth to 24 months gender specific growth charts. > 5th percentile and ≤ 10th percentile stature-for-age for children age 2-5 years as plotted on the 2000 CDC age/gender specific growth charts. For premature infants and children up to years of age, assignment of this risk criterion will be based on adjusted gestational age once the infant has reached the equivalent age of 40 weeks gestation. Nutrition Risk Code Table October 2025

Nutrition Risk Codes Category/Priority Code Description P B N I C 1 131* LOW MATERNAL WEIGHT GAIN Low maternal weight gain is defined as: 1. A low rate of weight gain, such that in the 2nd and 3rd trimesters, for singleton pregnancies: Pre-pregnancy Weight Groups BMI Definition Total Weight Gain (lbs)/Week Underweight < 18.5 < 1 Normal Weight 18.5 to 24.9 < 0.8 Overweight 25.0 to 29.9 < 0.5 Obese ≥ 30.0 < 0.4 OR 2. Low weight gain at any point in pregnancy, such that a pregnant woman’s weight plots at any point beneath the bottom line of the appropriate weight gain range, according to the Institute of Medicine (IOM)-based weight gain grid, for her respective pre-pregnancy weight category as follows: Pre-pregnancy Weight Groups BMI Definition Total Weight Gain Range (lbs) Underweight < 18.5 28 – 40 Normal Weight 18.5 to 24.9 25 – 35 Overweight 25.0 to 29.9 15 – 25 Obese ≥ 30.0 11 – 20 This risk code may not be assigned for multi-fetal pregnancies (twin, triplets, etc.). For twin gestations, the 2009 IOM recommendations provide provisional guidelines: normal weight women should gain 37-54 pounds; overweight women, 31-50 pounds; and obese women, 25-42 pounds. Guidelines for underweight women were not developed. In triplet pregnancies, the overall gain should be around 50 pounds with a steady rate of gain of approximately 1.5 pounds per week throughout the pregnancy. Nutrition Risk Code Table October 2025

Nutrition Risk Codes Category/Priority Code Description P B N I C 1 1 6 133* HIGH MATERNAL WEIGHT GAIN Pregnant Women: 1. A high rate of weight gain, such that in the 2nd and 3rd trimesters, for singleton pregnancies: Pre-pregnancy Weight Groups BMI Definition Total Weight Gain (lbs)/Week Underweight < 18.5 BMI > 1.3 Normal Weight 18.5 to 24.9 BMI > 1 Overweight 25.0 to 29.9 BMI > 0.7 Obese ≥ 30.0 > 0.6 OR 2. High weight gain at any point in the pregnancy, such that using an IOM based weight gain grid, a pregnant woman’s weight plots above the top line of the appropriate weight gain range for her respective pre-pregnancy weight category. Breastfeeding/Non-Breastfeeding Women (most recent pregnancy): Total gestational weight gain exceeding the upper limit of the IOM recommended range based on BMI for singleton pregnancies, as follows: Pre-pregnancy Weight Groups BMI Definition Cut-off Value Underweight < 18.5 BMI > 40 lbs Normal Weight 18.5 to 24.9 BMI > 35 lbs Overweight 25.0 to 29.9 BMI > 25 lbs Obese ≥ 30.0 > 20 lbs This risk code may not be assigned for multi-fetal pregnancies (twin, triplets, etc.) For twin gestations, the 2009 IOM recommendations provide provisional guidelines: normal weight women should gain 37-54 pounds; overweight women, 31-50 pounds; and obese women, 25-42 pounds. Guidelines for underweight women were not developed. In triplet pregnancies, the overall gain should be around 50 pounds with a steady rate of gain of approximately 1.5 pounds per week throughout the pregnancy. Nutrition Risk Code Table October 2025

Nutrition Risk Codes Category/Priority Code Description P B N I C 1 3 134 FAILURE-TO-THRIVE Presence of failure to thrive (FTT) diagnosed, documented, or reported by a physician or someone working under a physician’s orders, or as self-reported by applicant/participant/caregiver. 1 135° SLOWED/FALTERING GROWTH PATTERN Slowed/Faltering Growth is defined as: Age Cut-Off Values Infants Birth to 2 Weeks Excessive weight loss after birth, defined as ≥ 7% birth weight. Infants 2 weeks to 6 months Any weight loss. Use two separate weight measurements taken at least eight weeks apart. 1 3 141* LOW BIRTH WEIGHT AND VERY LOW BIRTH WEIGHT Low Birth Weight: Birth weight ≤ 5 pounds 8 oz. (≤ 2500 g), for infants and children less than 24 months. Very Low Birth Weight: Birth weight < 3 pounds 5 ounces (< 1500 g), for infants and children less than 24 months. 1 3 142° PRETERM OR EARLY TERM DELIVERY Preterm: Delivery of an infant born ≤ 36 6/7 weeks gestation. Early Term: Delivery of an infant born ≥37 0/7 and ≤ 38 6/7 weeks gestation. 1 3 151 SMALL FOR GESTATIONAL AGE Infants and children less than 24 months of age diagnosed as small for gestational age. 1 153° LARGE FOR GESTATIONAL AGE Birth weight ≥ 9 pounds (≥ 4000g); or Presence of large for gestational age. Nutrition Risk Code Table October 2025

Nutrition Risk Codes Category/Priority Code Description P B N I C 1 1 6 1 3 201* LOW HEMATOCRIT/HEMOGLOBIN Hemoglobin or hematocrit concentration below the 95 percent confidence interval for healthy, well-nourished individuals of the same age, sex, and stage of pregnancy. Adjustments for participant smoking and clinic altitude are considered in cut-off value determination. These cut-off values are provided. See Attachment Anemia Cut-Off Values. 1 1 6 1 3 211* ELEVATED BLOOD LEAD LEVELS Blood lead level of ≥5 µg/dL within the past 12 months. 1 301 HYPEREMESIS GRAVIDARUM Severe and persistent nausea and vomiting during pregnancy which may cause more than 5% weight loss and fluid and electrolyte imbalances. This nutrition risk is based on a chronic condition, not single episodes. This is a clinic diagnosis, made after other causes of nausea and vomiting have been excluded. 1 302° GESTATIONAL DIABETES Gestational diabetes mellitus (GDM) is defined as any degree of glucose/carbohydrate intolerance with onset or first recognition during pregnancy. 1 1 6 303° HISTORY OF GESTATIONAL DIABETES History of diagnosed gestational diabetes mellitus (GDM). 1 1 6 304° HISTORY OF PREECLAMPSIA History of diagnosed preeclampsia. 1 1 6 311* HISTORY OF PRETERM OR EARLY TERM DELIVERY Preterm: Delivery of an infant ≤36 6/7 weeks. Early Term: Delivery of an infant born ≥ 37 0/7 and ≤ 38 6/7 weeks. Nutrition Risk Code Table October 2025

Nutrition Risk Codes Category/Priority Code Description P B N I C 1 1 6 321* HISTORY OF SPONTANEOUS ABORTION, FETAL OR NEONATAL LOSS History of spontaneous abortion, fetal or neonatal loss are defined as follows: Pregnant Women: Any history of fetal or neonatal death or 2 or more spontaneous abortions. Breastfeeding: Most recent pregnancy in which there was a multifetal gestation with one or more fetal or neonatal deaths but with one or more infants still living. Non-Breastfeeding Women: Spontaneous abortion, fetal or neonatal loss in most recent pregnancy. Spontaneous abortion, fetal and neonatal death are defined as follows: Spontaneous Abortion (SAB): The spontaneous termination of a gestation at < 20 weeks or of a fetus weighing < 500 grams. Fetal Death: The spontaneous termination of a gestation at ≥ 20 weeks. Neonatal Death: The death of an infant within 0-28 days of life. 1 1 3 331* PREGNANT AT A YOUNG AGE Conception ≤ 20 years of age for the following: Pregnant Women: Current pregnancy. Breastfeeding/ Non-Breastfeeding Women: Most recent pregnancy. 1 1 6 332* SHORT INTERPREGNANCY INTERVAL Interpregnancy interval of less than 18 months from the date of a live birth to the conception of the subsequent pregnancy. 1 1 6 335° MULTIFETAL GESTATION More than one (> 1) fetus in a current pregnancy (Pregnant Women) or the most recent pregnancy (Breastfeeding/Non-Breastfeeding Women). 1 336 FETAL GROWTH RESTRICTION May be diagnosed by a physician with serial measurements of fundal height, abdominal girth and can be confirmed with ultrasonography. FGR is usually defined as a fetal weight < 10th percentile for gestational age. Nutrition Risk Code Table October 2025

Nutrition Risk Codes Category/Priority Code Description P B N I C 1 1 6 337° HISTORY OF A BIRTH OF A LARGE FOR GESTATIONAL AGE INFANT History of birth of a large for gestational age infant is defined as follows: Pregnant Women: Any history of giving birth to an infant weighing greater than or equal to 9 lbs. (4000 grams). Breastfeeding/Non-Breastfeeding Women: Most recent pregnancy, or history of giving birth to an infant weighing greater than or equal to 9 lbs. (4000 grams). 1 338 PREGNANT WOMAN CURRENTLY BREASTFEEDING Breastfeeding woman now pregnant. 1 1 6 339 HISTORY OF BIRTH WITH NUTRITION RELATED CONGENTIAL OR BIRTH DEFECT A woman who has given birth to an infant with a congenital or birth defect linked to inappropriate nutritional intake, (i.e., inadequate Zinc, Folic acid, excess vitamin A). Pregnant Women: Any history of birth with nutrition-related congenital or birth defect. Breastfeeding/Non-Breastfeeding Women: Most recent pregnancy. 1 1 6 1 3 341 NUTRIENT DEFICIENCY OR DISEASES Any currently treated or untreated nutrient deficiency or disease. This includes, but are not limited to, Protein Energy Malnutrition, Scurvy, Rickets, Berberi, Hypocalcemia, Osteomalacia, Vitamin K Deficiency, Pellagra, Xerophthalmia, and Iron Deficiency. 1 1 6 1 3 342 GASTROINTESTINAL DISORDERS Disease and/or condition that interferes with the intake or absorption of nutrients. The diseases and/or conditions include, but are not limited to: • Gastroesophageal reflux disease (GERD) • Peptic ulcer • Post-bariatric surgery • Short bowel syndrome • Inflammatory bowel disease, including ulcerative colitis or Crohn’s disease • Liver disease • Pancreatitis • Biliary tract diseases Nutrition Risk Code Table October 2025

Nutrition Risk Codes Category/Priority Code Description P B N I C 1 1 6 1 3 343° DIABETES MELLITUS • Diabetes mellitus consists of a group of metabolic diseases characterized by inappropriate hyperglycemia resulting from defects in insulin secretion, insulin action or both. Does not include Gestational Diabetes. 1 1 6 1 3 344 THYROID DISORDERS Thyroid dysfunctions that occur in pregnant or postpartum women, during fetal development, and in childhood that are caused by the abnormal secretion of thyroid hormone. Medical conditions include, but are not limited to: • Hyperthyroidism (excess thyroid hormone production, includes congenital hyperthyroidism) • Hypothyroidism (low secretion of thyroid hormone, includes congenital hypothyroidism) • Congenital Hyperthyroidism (Excessive thyroid hormone levels at birth) • Congenital Hypothyroidism (Infants born with an under active thyroid gland) • Postpartum thyroiditis 1 1 6 1 3 345 HYPERTENSION AND PRE-HYPERTENSION • Hypertension is defined as high blood pressure which may eventually cause health problems and includes chronic hypertension during pregnancy, preeclampsia, eclampsia, chronic hypertension with superimposed preeclampsia, and gestational hypertension. Prehypertension is defined as being at high risk for developing hypertension, based on blood pressure levels. 1 1 6 1 3 346 RENAL DISEASE Any renal disease including pyelonephritis and persistent proteinuria but excluding urinary tract infections (UTI) involving the bladder. 1 1 6 1 3 347 CANCER A chronic disease whereby populations of cells have acquired the ability to multiply and spread without usual biological restraints. The current condition, or treatment for the condition, must be severe enough to affect nutrition status. Nutrition Risk Code Table October 2025

Nutrition Risk Codes Category/Priority Code Description P B N I C 1 1 6 1 3 348 CENTRAL NERVOUS SYSTEM DISORDERS Condition which affects energy requirements, ability to feed self, or alters nutritional status metabolically, mechanically, or both. Includes, but is not limited to: • Epilepsy • Cerebral Palsy (CP) • Neural tube defects (NTD) • Parkinson’s disease, and • Multiple sclerosis (MS) 1 1 6 1 3 349 GENETIC AND CONGENITAL DISORDERS Hereditary or congenital condition at birth that causes physical or metabolic abnormality. The current condition must alter nutritional status metabolically, mechanically, or both. Includes, but is not limited to: • Cleft lip or palate • Down’s syndrome • Thalassemia major • Sickle cell anemia, and • Muscular dystrophy 1 1 6 1 3 351 INBORN ERRORS OF METABOLISM Inherited metabolic disorders caused by a defect in the enzymes or their co-factors that metabolize protein, carbohydrate or fat. Generally, refers to gene mutations or gene deletions that alter metabolism in the body, includes, but not limited to: • Galactosemia, • Tyrosinemia, • Homocystinuria, • Phenylketonuria (PKU) • Maple syrup urine disease, and • Glycogen storage disease Call the WIC State Nutritionist to discuss other possible disorders. Nutrition Risk Code Table October 2025

Nutrition Risk Codes Category/Priority Code Description P B N I C 1 1 6 1 3 352a INFECTIOUS DISEASES - Acute A disease which is characterized by a single or repeated episode of relatively rapid onset and short duration within the past six months. Infectious disease come from bacteria, viruses, parasites, or fungi and spread directly or indirectly from person to person. These diseases and or conditions include, but are not limited to: • Hepatitis A & E • Listeriosis • Pneumonia • Parasitic infections • Meningitis, and • Bronchiolitis (3 episodes in last 6 months) 1 1 6 1 3 352b Infectious Diseases – Chronic Conditions likely lasting a lifetime and require long term management of symptoms. Infectious disease come from bacteria, viruses, parasites, or fungi and spread directly or indirectly, from person to person. These diseases and/or conditions include but are not limited to: • HIV/AIDS • Hepatitis B • Hepatitis C • Hepatitis D 1 1 6 1 3 353 FOOD ALLERGIES An adverse health effect arising from a specific immune response that occurs reproducibly on exposure to a given food. This code should not be assigned to those who have non-immunologic adverse reactions to food (ex: intolerances or sensitives). 1 1 6 1 3 354 CELIAC DISEASE An autoimmune disease precipitated by the ingestion of gluten (a protein found in wheat, rye, and barley) that results in damage to the small intestine and malabsorption of the nutrients from food. Celiac disease is also known as celiac sprue, gluten-sensitive enteropathy, and non-tropical sprue. 1 1 6 1 3 355 LACTOSE INTOLERANCE Lactose intolerance is the syndrome of one or more of the following: diarrhea, abdominal pain, flatulence, and/or bloating that occurs after ingestion of lactose containing products. Nutrition Risk Code Table October 2025

Nutrition Risk Codes Category/Priority Code Description P B N I C 1 1 6 1 3 356 HYPOGLYCEMIA Presence of hypoglycemia diagnosed, documented, or reported by a physician or someone working under a physician’s orders, or as self-reported by applicant/participant/caregiver. 1 1 6 1 3 357 DRUG NUTRIENT INTERACTION Use of prescription or over-the-counter drugs or medications that have been shown to interfere with nutrient intake, absorption, distribution, metabolism, or excretion, to an extent that nutritional status is compromised. 1 1 6 358 EATING DISORDERS Eating disorders (anorexia nervosa, bulimia nervosa, or binge-eating disorder) are characterized by severe disturbances in a person’s eating behaviors and related thoughts and emotions.. Symptoms are manifested by abnormal eating patterns including, but not limited to: • Self-induced vomiting • Purgative abuse • Alternating periods of starvation • Use of drugs such as appetite suppressants, thyroid preparations, or diuretics for weight reduction • Self-induced marked weight loss 1 1 6 1 3 359 RECENT MAJOR SURGERY, TRAUMA, BURNS Major surgery (including c-sections), trauma or burns severe enough to compromise nutritional status. • Any occurrence within the past two (≤ 2) months may be self-reported. More than two (≥ 2) months previous must have the continued need for nutritional support diagnosed by a physician or health care provider working under the orders of a physician. Nutrition Risk Code Table October 2025

Nutrition Risk Codes Category/Priority Code Description P B N I C 1 1 6 1 3 360 OTHER MEDICAL CONDITIONS Diseases or conditions with nutritional implications that are not included in any of the other medical conditions. The current condition, or treatment for the condition, must be severe enough to affect nutrition status. This includes, but is not limited to: • Juvenile idiopathic arthritis (JIA) • Systemic lupus erythematosus (SLE) • Cardiorespiratory disease • Heart disease • Cystic fibrosis • Persistent asthma (moderate or severe) requiring daily medication • Polycystic Ovary Syndrome (PCOS) This code will usually not be applicable for infants for the medical condition of asthma. In infants, asthma-like symptoms are usually diagnosed as bronchiolitis with wheezing which is covered under code 352. 1 1 6 1 3 361 MENTAL ILLNESS Presence of a mental health disorder as defined by the American Psychiatric Association in the DSM-V. Mental illness where the current condition, or treatment for the condition may affect nutrition status include, but are not limited to: - Depression - Anxiety disorders - Post-traumatic stress disorder (PTSD) - Obsessive-compulsive disorder (OCD) - Personality disorders - Bipolar disorders - Schizophrenia - Attention-deficit/hyperactivity disorder (ADHD) 1 1 6 1 3 362 DEVELOPMENTAL, SENSORY OR MOTOR DISABILITIES INTERFERING WITH THE ABILITY TO EAT Developmental, sensory, or motor disabilities that restrict the ability to intake, chew, or swallow food or require tube feeding to meet nutritional needs. These may include birth injury, head trauma, brain damage, minimal brain function, pervasive developmental disability (which may include autism) and other disabilities. 1 6 363 PRE-DIABETES Impaired fasting glucose (IFG) and/or impaired glucose tolerance (IGT) as referred to as pre-diabetes. These conditions are characterized by hyperglycemia that does not meet the diagnostic criteria for diabetes mellitus. Nutrition Risk Code Table October 2025

Nutrition Risk Codes Category/Priority Code Description P B N I C 1 1 6 371* NICOTINE AND TOBACCO USE Any use of products that contain nicotine and/or tobacco to include but not limited to cigarettes, pipes, cigars, electronic nicotine delivery systems (e-cigarettes, vaping devices), hookahs, smokeless tobacco (chewing tobacco, snuff, dissolvable), or nicotine replacement therapies (gums, patches). 1 1 6 372° ALCOHOL AND SUBSTANCE USE Pregnant Women: • Any alcohol use • Any illegal substance use and/or abuse of prescription medications • Any marijuana use in any form Breastfeeding/Non-Breastfeeding Postpartum Women: • Alcohol Use: o High Risk Drinking: Routine consumption of ≥8 drinks per week or ≥4 drinks on any day. o Binge Drinking: Routine consumption of ≥4 drinks within 2 hours. Note: A serving, or standard sized drink is: 12 oz beer; 5 oz wine; or 1 ½ fluid ounces 80 proof distilled spirits (e.g., gin, rum, vodka, whiskey, cordials, or liqueurs). • Any illegal substance use and/or abuse of prescription medications. • Any marijuana use in any form (breastfeeding women only). 1 1 6 1 3 381 ORAL HEALTH CONDITIONS Oral health conditions include, but is not limited to: • Dental caries ("cavities", "tooth decay") • Periodontal disease ("gingivitis, "periodontis") Tooth loss- ineffectively replaced teeth or oral infections which impair the ability to ingest food in adequate quantity or quality. 1 3 382 FETAL ALCOHOL SPECTRUM DISORDERS • Fetal alcohol spectrum disorders (FASDs) are a group of conditions that can occur in a person whose mother consumed alcohol during pregnancy. FASDs is an overarching phrase that encompasses a range of possible diagnoses, including fetal alcohol syndrome (FAS), partial fetal alcohol syndrome (pFAS), alcohol-related birth defects (ARBD), alcohol-related neurodevelopmental disorder (ARND), and neurobehavioral disorder associated with prenatal alcohol exposure. Nutrition Risk Code Table October 2025

Nutrition Risk Codes Category/Priority Code Description P B N I C 1 383 NEONATAL ABSTINENCE SYNDROME (NAS) Drug withdrawal syndrome that occurs among drug-exposed (primarily opioid-exposed) infants as a result of the mother’s use of drugs during pregnancy. NAS is a combination of physiologic and neurologic symptoms that can be identified immediately after birth and can last up to 6 months after birth. This condition must be present within the first 6 months of birth and diagnosed, documented, or reported by a physician or someone working under a physician’s orders, or self-reported by the infant’s caregiver. 4 4 6 5 401 FAILURE TO MEET USDA/US DEPARTMENT OF HEALTH AND HUMAN SERVICES DIETARY GUIDELINES FOR AMERICANS Women and children two years of age and older who meet the income, categorical, and residency eligibility requirements may be presumed to be at nutrition risk for failure to meet Dietary Guidelines for Americans [Dietary Guidelines] (1). Based on an individual’s estimated energy needs, the failure to meet Dietary Guidelines risk criterion is defined as consuming fewer than the recommended number of servings from one or more of the basic food groups (grains, fruits, vegetables, milk products, and meat or beans). This can only be used when a complete nutrition assessment has been completed, and no other risk criteria have been identified. Nutrition Risk Code Table October 2025

Nutrition Risk Codes Category/Priority Code Description P B N I C 4 411 INAPPROPRIATE NUTRITION PRACTICES FOR INFANTS Routine use of feeding practices that may result in impaired nutrient status, disease, or health problems. For an infant, routine use of any of the following: • Using a substitute(s) for breast milk or for FDA fortified formula as the primary nutrient source during the first year of life. Examples include feeding goat’s milk, sheep’s milk, cow’s milk, evaporated milk, sweetened condensed milk, imitation milk, substitute milks, or low iron formula • Using nursing bottles or cups improperly. Examples include using a bottle to feed fruit juice; feeding any sugar- containing fluids; allowing the infant to fall asleep or be put to bed with a bottle; allowing use of bottle without restriction; propping the bottle when feeding; allowing an infant to carry around and drink throughout the day with a covered training cup; adding any food to the infant's bottle. • Offering complimentary foods or other substances that are inappropriate in type or timing. Examples include adding any sweet agents (sugar, honey, or syrups) to any beverage (including water) or prepared food, or used on pacifier, introducing any food other than human milk or iron fortified infant formula before 6 months of age. • Using feeding practices that disregard the developmental needs or stage of the infant. Examples: inability to recognize or insensitivity to infant's feeding cues (hunger or satiety); feeding foods of inappropriate consistency, texture, size or shape that may put them at risk of choking; not supporting the infant's need for growing independence with self-feeding. • Feeding foods to an infant that could be contaminated with harmful microorganisms or toxins. Examples: unpasteurized fruit or vegetable juice, dairy products; honey' raw or undercooked meat, fish, poultry, or eggs; raw vegetable sprouts; and deli meats, hot dogs, and processed meats (unless heated until steaming hot); Donor human milk acquired directly from individuals or the internet. • Feeding inappropriately diluted formula. Examples: failure to follow manufacturer's instructions for mixing formula or failure to mix according to accompanying prescription. Nutrition Risk Code Table October 2025

Nutrition Risk Codes Category/Priority Code Description P B N I C 4 411 INAPPROPRIATE NUTRITION PRACTICES FOR INFANTS- CONTINUED • Routinely limiting the frequency of nursing of the exclusively breastfed infant when human milk is the sole source of nutrients. Examples: scheduled feedings instead of demand feedings; less than 8 feedings per 24 hours if less than 2 months of age. • Feeding a diet very low in calories and/or essential nutrients Examples: Strict vegan or macrobiotic diet or other diets very low in calories and/or essential nutrients. • Using inappropriate sanitation in the feeding, preparation, handling, and storage of expressed human milk or formula. Examples: limited or no access to fresh water supply, heat source or refrigerator or freezer; failure to properly prepare, handle, and store bottles, storage containers or breast pumps properly; Human Milk: thawing/heating in a microwave, refreezing, adding freshly expressed unrefrigerated human milk to frozen human milk, adding freshly pumped chilled human milk to frozen human milk in an amount that is greater than the amount of the frozen human milk, feeding thawed refrigerated human milk more than 24 hours after it was thawed, saving human milk from a used bottle for another feeding, failure to clean breast pump per manufacturer’s instructions, and feeding donor human milk acquired directly from individuals or the internet. Formula: failure to prepare and/or store formula per manufacturer’s or physician instructions, storing at room temperature for more than 1 hour, using formula in a bottle one hour after the start of a feeding, saving formula from a used bottle for another feeding, and failure to clean baby bottle properly. • Feeding dietary supplements with potentially harmful consequences (i.e., in excess). Examples: Single or multi-vitamins, minerals, and herbal or botanical supplements/remedies/teas. • Not providing dietary supplements recognized as essential by national public health policy when an infant's diet alone cannot meet nutrient requirements. Examples: Infants who are 6 months of age or older who are ingesting less than 0.25 mg of fluoride daily when the water supply contains less than 0.3 ppm fluoride; infants who are exclusively breastfed, or who are ingesting less than 1 liter per day of vitamin D fortified infant formula and are not taking a supplement of 400 IU of vitamin D. These justifications apply only if the infant is developmentally correct for age. Documentation in the participant folder must include the basis for code selection. Nutrition Risk Code Table October 2025

Nutrition Risk Codes Category/Priority Code Description P B N I C 5 425 INAPPROPRIATE FEEDING PRACTICES FOR CHILDREN Routine use of feeding practices that may result in impaired nutrient status, disease, or health problems. For a child, routine use of any of the following: • Feeding inappropriate beverages as the primary milk source Examples: Non-fat or reduced fat milks (between 12-24 months of age only) unless the appropriate tailoring of the food package has been assigned, sweetened condensed milk and goat’s milk, sheep’s milk, imitation or substitute milks, or other homemade concoctions. • Feeding a child any sugar-containing fluids Examples: Soda/soft drinks, gelatin water, corn syrup solutions, and sweetened tea. • Using nursing bottles, cups, or pacifiers improperly Examples: using a bottle to feed fruit juice, cereal or other solid foods; allowing the child to fall asleep or be put to bed with a bottle at naps or bedtime; allowing the child to use a bottle without restriction or as a pacifier; and, using a bottle for feeding or drinking beyond 14 months of age • Using feeding practices that disregard the developmental needs or stages of the child Example: Inability to recognize, insensitivity to or disregarding the child’s cues for hunger and satiety, feeding foods of inappropriate consistency, size, or shape that put the children at risk of choking, not supporting a child’s need for growing independence with self-feeding, and feeding a child food with an inappropriate texture based on his/her developmental stage. • Feeding foods to a child that could be contaminated with harmful microorganisms Examples: unpasteurized fruit or vegetable juice; unpasteurized dairy products; raw or undercooked meat, fish, poultry or eggs; raw vegetable sprouts; deli meats, hot dogs and processed meats that are not heated until steaming hot. • Feeding a diet very low in calories and/or essential nutrients Examples: vegan or macrobiotic diet or other diets very low in calories and/or essential nutrients. • Feeding dietary supplements with potentially harmful consequences (i.e.in excess) Examples: single or multi-vitamin, mineral or herbal/botanical supplements/remedies or teas. Nutrition Risk Code Table October 2025

Nutrition Risk Codes Category/Priority Code Description P B N I C 5 425 INAPPROPRIATE FEEDING PRACTICES FOR CHILDREN- CONTINUED • Not providing dietary supplements recognized as essential by national public health policy when a child's diet alone cannot meet nutrient requirements Examples: providing children under 36 months of age less than 0.25 mg of fluoride daily when the water supply contains less than 0.3 pp, fluoride; providing children 36-60 months of age less than 0.50 mg of fluoride daily when the water supply contains less than 0.3 ppm fluoride; and, not providing 400 IU of vitamin D per day if a child consumes less than 1 liter (1 quart) of vitamin D fortified milk or formula. • Ingestion of non-food items (pica) Examples: Ashes, carpet fibers, cigarettes or cigarette butts, clay, dust, foam rubber, paint chips, soil and starch (laundry and cornstarch). Documentation in the participant folder must include the basis for code selection. Continued on next page Nutrition Risk Code Table October 2025

Nutrition Risk Codes Category/Priority Code Description P B N I C 4 4 6 427 INAPPROPRIATE NUTRITION PRACTICES FOR WOMEN Routine nutrition practices that may result in impaired nutrient status, disease, or health problems. These practices, with examples, are outlined below. • Consuming dietary supplements with potentially harmful consequences (i.e. in excess) Examples: single or multi-vitamin, mineral or herbal/botanical supplements/remedies or teas, CBD (CBD- preg/BF women only). • Consuming a diet very low in calories and/or essential nutrients; or impaired caloric intake or absorption of essential nutrients following bariatric surgery Examples: Strict vegan diet, low-calorie diet, and any other diet restricting calories and/or essential nutrients. • Compulsively ingesting non-food items (pica) Examples: Cigarette ashes, baking soda, burnt matches, chalk, clay, coffee grounds, dirt, large quantities of ice and/or freezer frost, paper, starch (laundry and cornstarch), uncooked rice. • Inadequate vitamin/mineral supplementation recognized as essential by national public health policy Examples: - Pregnant: Consumption of less than 27mg of iron as a supplement daily - Pregnant or Breastfeeding: Consumption of less than 150µg of supplemental iodine per day - All Women Categories: Consumption of less than 400-800µg of folic acid from fortified foods and/or supplements daily • Pregnant woman ingesting foods that could be contaminated with pathogenic microorganisms Examples: - Unpasteurized fruit or vegetable juice - Unpasteurized dairy products - Raw or undercooked meat, fish, shellfish, poultry or eggs - Raw vegetable sprouts - Pates or unpasteurized meat spreads - Deli meats, hot dogs and processed meats that are not heated until steaming hot - Deli salads without preservatives - Unwashed fruits and vegetables Documentation in the participant folder must include the basis for code selection. Nutrition Risk Code Table October 2025

Nutrition Risk Codes Category/Priority Code Description P B N I C 4 5 428 DIETARY RISK ASSOCIATED WITH COMPLEMENTARY FEEDING PRACTICES For infants ≥ 4 months of age and children < 24 months of age at date of certification is at risk of inappropriate complementary feeding when he/she has begun to or is expected to begin to: • Consume complementary foods and beverages. • Eat independently. • Be weaned from breast milk or infant formula. • Transition from a diet based on infant/toddler foods to one based on the Dietary Guidelines for Americans. A complete nutrition assessment, including a for risk #411, Inappropriate Nutrition Practices for Infants, or #425 Inappropriate Nutrition Practices for Children, must be completed prior to assigning this risk. 1 3 1 3 501 POSSIBILITY OF REGRESSION A participant who has previously been certified eligible for the Program may be at nutritional risk in the next certification period if the competent professional authority determines there is a possibility of regression in nutritional status without the benefits that the WIC Program provides. The State may limit the number of times and circumstances under which a participant may be certified due to the possibility of regression. 1 1 3 1 3 502* TRANSFER OF CERTIFICATION Person with a current valid Verification of Certification (VOC) document from another state or local agency. The VOC is valid through the end of the current certification period, even if the participant does not meet the receiving agency’s nutritional risk, priority, or income criteria, or the certification period extends beyond the receiving agency’s certification period for that category and shall be accepted as proof of eligibility for Program benefits. If the receiving agency is at maximum caseload, the transferring participant must be placed at the top of any waiting list and enrolled as soon as possible. This criterion would be used primarily when the VOC card/document does not reflect another (more specific) nutrition risk condition or if the participant was certified based on a nutrition risk condition not in use by the receiving State agency. 4 503 PRESUMPTIVE ELIGIBILITY FOR PREGNANT WOMEN A pregnant woman who meets WIC income eligibility standards but has not yet been evaluated for nutrition risk, for a period of up to 60 days. Nutrition Risk Code Table October 2025

Nutrition Risk Codes Category/Priority Code Description P B N I C 1 2 4 1 2 4 601 BREASTFEEDING MOTHER OF INFANT AT NUTRITIONAL A breastfeeding woman breastfed infant has been determined to be at nutritional risk. Must be the same priority as at-risk infant. 1 1 602 BREASTFEEDING COMPLICATIONS OR POTENTIAL COMPLICATIONS (WOMEN) A breastfeeding woman with any of the following complications or potential complications: • Severe breast engorgement • Recurrent plugged ducts • Mastitis (fever or flu-like symptoms with localized breast tenderness) • Flat or inverted nipples • Cracked, bleeding or severely sore nipples • Age > 40 • Failure of milk to come in by 4 days postpartum • Tandem nursing (breastfeeding two siblings who are not twins) A woman experiencing breastfeeding complications must be referred for lactation counseling and/or, if appropriate, to her health care provider. 1 603 BREASTFEEDING COMPLICATIONS OR POTENTIAL COMPLICATIONS (INFANT) A breastfed infant with any of the following complications or potential complications: • Jaundice • Weak or ineffective suck. • Difficulty latching onto mother’s breast. • Inadequate stooling (for age, as determined by a physician or other health care professional), and/or less than 6 wet diapers per day. An infant with breastfeeding complications must be referred for lactation counseling and/or, if appropriate, to her/his health care provider. Nutrition Risk Code Table October 2025

Nutrition Risk Codes Category/Priority Code Description P B N I C 2 701° INFANT UP TO 6 MONTHS OLD OF WIC MOTHER, OR OF A WOMAN WHO WOULD HAVE BEEN ELIGIBLE DURING PREGNANCY An infant < 6 months of age whose mother was a WIC program participant during pregnancy or whose mother’s medical records document that the woman was at nutritional risk during pregnancy because of detrimental or abnormal nutritional conditions detectable by biochemical or anthropometric measurements or other documented nutritionally related medical conditions. 1 2 4 702 BREASTFEEDING INFANT OF WOMAN AT NUTRITIONAL RISK A breastfed infant of woman at nutritional risk. Must be the same priority as at-risk mother. 4 4 6 4 5 801° HOMELESSNESS 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 designed to provide temporary living • 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 A public or private place not designed for or ordinarily used as a regular sleeping accommodation for human beings. 4 4 6 4 5 802° MIGRANCY Categorically eligible women, infants or children who are members of families which contain at least one 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. Nutrition Risk Code Table October 2025

Nutrition Risk Codes Category/Priority Code Description P B N I C 4 4 6 4 5 901 RECIPIENT OF ABUSE An individual who has experienced physical, sexual, emotional, economic, or psychological maltreatment at any point in time that may frighten, intimidate, terrorize, manipulate, hurt, humiliate, blame, injure, and/or wound the individual. The experience of abuse may be self-reported by the individual, an individual’s family member, or reported by a social worker, healthcare provider, or other appropriate personnel. Types of abuse include, but are not limited to, the following: - Domestic violence- abuse committed by a current or former family or household member or intimate partner - Intimate partner violence- a form of domestic violence committed by a current or former intimate partner that may include physical violence, sexual violence, stalking, and/or psychological aggression (including coercive tactics) - Child abuse and/or neglect- any failure to act that results in harm toa child or puts a child at risk of harm. Child abuse may be physical, sexual, or emotional abuse or neglect of a person under the age of 18 by a parent, caretaker, or other person in a custodial role. Abuse must be well documented in the participant record and WIC staff must follow Montana State Law requiring the reporting of known or suspected child abuse or neglect. 4 4 6 4 5 902 WOMAN OR INFANT/CHILD OF PRIMARY CAREGIVER WITH LIMITED ABILITY TO MAKE FEEDING DECISIONS AND/OR PREPARE FOOD Woman (pregnant, breastfeeding, or non-breastfeeding) or infant/child whose primary caregiver is assessed to have a limited ability to make appropriate feeding decisions and/or prepare food. Examples include, but are not limited to, a woman or an infant/child of caregiver with the following: • Documentation or self-reported of misuse of alcohol, use of illegal substances, use of marijuana, or misuse of prescription medications. • Mental illness, including clinical depression diagnosed, documented, or reported by a physician or psychologist or someone working under a physician’s orders or as self-reported by applicant/participant/caregiver. • Intellectual disability diagnosed, documented, or reported by a physician or psychologist or someone working under a physician’s orders, or as self-reported by applicant/participant/caregiver. • ≤ 17 years of age. • Physically disabled to a degree which impairs ability to feed infant/child or limits food preparation abilities. Nutrition Risk Code Table October 2025

Nutrition Risk Codes Category/Priority Code Description P B N I C 4 4 6 4 5 903 FOSTER CARE Woman (pregnant, breastfeeding, non-breastfeeding) or infant/child who has entered the foster care system during the previous six months or moved from one foster care home to another foster care home during the previous six months. 1 1 6 1 3 904* ENVIRONMENTAL TOBACCO SMOKE EXPOSURE Environmental tobacco smoke (ETS) exposure is defined (for WIC eligibility purposes) as exposure to smoke from tobacco products inside enclosed areas, like the home, place of childcare, etc. ETS is also known as second-hand, passive, or involuntary smoke. The ETS definition also includes the exposure to the aerosol from electronic nicotine delivery systems. Nutrition Risk Code Table October 2025

Participant Rights and Responsibilities Form

Participant Rights and Responsibilities Statement

October 2025

INSTRUCTIONS: Please read this form and then sign. If you do not understand any part of it, please ask for help.

I Agree To: o Attend and be on time for all appointments. o Let WIC staff know in advance if I cannot keep an appointment. o Provide accurate and correct information to WIC. o Let the WIC staff know if my address, phone number or income changes, if I am going to move away or if I no longer have custody of the child. o Handle my eWIC card carefully as replacing the card can take several days. o Report eWIC Cards that are lost, stolen, or destroyed. o Follow the shopping guidelines for using WIC benefits as specified in the program booklet. o Treat WIC staff and retail staff with respect and courtesy. Train my authorized representatives and proxies on WIC and eWIC Card procedures and policies. I am accountable for their actions. I Understand That: o WIC will give me benefits to buy certain foods from WIC authorized retailers each month. It is important that the benefits are picked up on time. If benefits are not picked up for two months in a row, I may be removed from the program. o WIC foods are specifically issued for the enrolled family member. o The local WIC program will make nutrition education and referrals to health services available to me and/or my child. I am encouraged to use these services. o My WIC information may be released to other programs and entities to determine eligibility, conduct outreach, enhance health education, streamline administrative procedures, or access and evaluate participant health care needs and outcomes. For a list of programs or entities that may receive your information, please ask WIC staff. o Receiving benefits from more than one WIC clinic at a time is illegal (dual participation).

o I may lose my WIC benefits if I, or an authorized individual, sell my eWIC Card; return WIC foods for cash or non-WIC foods; sell, trade, or give away WIC foods; buy non-WIC foods; use an unauthorized retailer; or verbally abuse WIC or retail staff. I also may be required to repay benefits. o Coordination with medical payors and other programs that provide or reimburse for formula is required. If I am receiving formula from a medical payor, I will inform WIC staff. o Standards for eligibility and participation in the WIC Program are the same for everyone, regardless of race, color, national origin, sex, disability, age, or reprisal or retaliation for prior civil rights activity in any program or activity conducted or funded by USDA. o I have 60 days to appeal any decision made by the local agency regarding my eligibility for the Program. A fair hearing will be conducted by a fair and impartial official according to 246.18 and applicable portions of Title 2, Chapter 4 Montana Code Annotated, whose decision will rest solely on the evidence presented at the hearing and statutory and regulatory provisions governing the WIC Program in Montana. I have been advised of my rights and responsibilities under the program. I certify that the information I have provided for my eligibility determination is correct, to the best of my knowledge. This certification form is being submitted in connection with the receipt of Federal assistance. Program officials may verify information on this form. I understand that intentionally making a false or misleading statement or intentionally misrepresenting, concealing, or withholding facts may result in paying the State agency, in cash, the value of food benefits improperly issued to me and may subject me to civil or criminal prosecution under State and Federal law.

This institution is an equal opportunity provider.

I have read and understand my rights and responsibilities for participation in the Montana WIC Program:

Signature of Participant/Authorized Representative

Date

Program Complaint Form Complete this form to report a program complaint to WIC. You may remain anonymous or provide your information (which would allow for follow-up). Please provide your contact information and a detailed description of the incident and submit the form to the State WIC Program. All complaints are treated with privacy, and confidentiality of the parties involved is maintained unless otherwise required by an investigation or proceeding. This program complaint is reported by: WIC Participant Retailer Farmer WIC Staff Other: Name of person reporting the complaint (optional): Phone or email (optional): Name of person filling out the form if different from above: Date of incident: Who is the complaint against? Location of Incident: (clinic, store, town, residence, etc.) Please describe in detail the incident that has occurred: I agree that this statement of allegations may be used during the investigation of the case. I further consent that this statement and certain information in the complaint file may be disclosed to certain agency employees including the person I believe discriminated against me in order to resolve my complaint, conduct fact finding, or implement remedial action. I also understand that information may be disclosed if required by law, rule, regulation, or court order. I affirm that this complaint statement is true, accurate, and complete to the best of my knowledge. Your Signature: Today’s Date: Mail or Fax to: Montana WIC Program PO Box 202951 The State Office will review this form and be in touch with follow-up instructions. Helena, MT 59620-2951 Phone: 1-800-433-4298 Fax: (406) 444-0239 Complaint Form October 2025 SIGN

USDA Nondiscrimination Statement 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/USDA-OASCR%20P-Complaint-Form-0508-0002­ 508-11-28-17Fax2Mail.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 Complaint Form October 2025

Program Compliance Form Instructions: 1) Program Complaint Form will be used to document any issue regarding the WIC Program 2) Program Complaint Form is sent to the State Office Integrity Staff for review and follow-up 3) State Staff will complete research and document findings on this form, send copy of this form, Program Complaint Form and back-up documentation to Local Agency Staff for necessary follow-up actions and/or documentation purposes. Date Reported: Name of Local Agency or Store: Complaint Against (name): ID or Store# (if applicable): Check One: □ WIC Participant □ WIC Staff □ Retailer Participant Violations (*Federally Required) Action Taken/Sanction Intentional misrepresentation of □ No action: unsubstantiated or unintentional circumstances to obtain benefits* □ Warning Letter/Counseling □ Value of Benefits Mis-used: □ 2nd Offense: □ 1st □ Disqualification (months): □ 3 or □ 12 Dual Participation* □ No action: unsubstantiated or unintentional □ 12-month disqualification □ Value of Benefits Mis-used: Receipt of, or attempt to receive, cash/credit toward unauthorized food/other item of value in lieu of authorized supplemental foods from a retailer* □ 2nd Offense: □ 1st □ No action: unsubstantiated or unintentional □ Warning Letter/Counseling □ 12-month disqualification Threatening to harm or physically harming clinic, farmer or vendor staff* □ No action: report could not be validated, or act was determined unintentional □ 12-month disqualification Attempt to sell or donate or exchange WIC issued and owned multi-user breast pumps □ No action: unsubstantiated or unintentional □ Warning Letter/Counseling (no property loss) □ Report to law enforcement □ Value of Pump: Verbal abuse or harassment of clinic, farmer or vendor staff Offense: □ 1st □ 2nd □ No action: unsubstantiated or unintentional □ Warning Letter/Counseling (no property loss) □ 12-month disqualification Other violation (describe): □ No action: unsubstantiated or unintentional □ Warning Letter/Counseling □ Disqualification for months WIC Staff Fraud/Abuse Action Taken Discourteous treatment and/or customer service problem Program Abuse/Fraud (describe): Program Compliance Form October 2025

Program Compliance Form Retailer Violations (*Federally Required) Action Taken/Sanction Conviction or occurrence of trafficking WIC benefits* □ No action: unsubstantiated or unintentional □ Disqualification: □ 1yr. □ 6yrs. □ Permanent Overcharging participants* □ 2nd Offense: □ 1st □ No action: unsubstantiated or unintentional □ Written notice, CAP and mandatory training □ 3-year disqualification Charging the WIC Program for foods not received by the participant* □ 2nd Offense: □ 1st □ No action: unsubstantiated or unintentional □ Written notice, CAP and mandatory training □ 3-year disqualification Providing unauthorized foods in exchange for WIC benefits* □ 2nd Offense: □ 1st □ No action: unsubstantiated or unintentional □ Written notice, CAP and mandatory training □ 1-year disqualification Providing credit or non-food items in exchange for WIC food benefits* Offense: □ 1st □ 2nd □ No action: unsubstantiated or unintentional □ Written notice, CAP and mandatory training □ 3-year disqualification Failure to stock any WIC items in three or □ No action: unsubstantiated or unintentional more required food categories □ Written notice, CAP, mandatory training, and verification that insufficient inventory has been corrected within 30d. Offense: □ 1st □ 2nd □ 3rd □ 1-year disqualification Failure to meet min. stock of WIC foods Offense: □ 1st □ 2nd □ 3rd □ 4th □ No action: unsubstantiated or unintentional □ Written notice; and □ Training: □ offered or □ mandatory □ CAP Required □ Verification that inventory has been corrected within 30 days □ 1-year disqualification Contacting WIC participant in attempt to □ No action: unsubstantiated or unintentional recover funds for WIC benefits not □ Written notice; and reimbursed or overcharges were requested □ Training: □ offered or □ mandatory □ CAP Required Offense: □ 1st □ 2nd □ 3rd □ 4th □ 1-year disqualification Failure to provide WIC participant itemized receipt for foods purchased with WIC benefit Offense: □ 1st □ 2nd □ 3rd □ 4th □ No action: unsubstantiated or unintentional □ Written notice; and □ Training: □ offered or □ mandatory □ CAP Required □ 1-year disqualification Giving change in a WIC transaction or □ No action: unsubstantiated or unintentional requiring cash to be paid in whole or in part □ Written notice; and to redeem WIC benefits □ Training: □ offered or □ mandatory □ CAP Required Offense: □ 1st □ 2nd □ 3rd □ 4th □ 1-year disqualification Verbal abuse or discourteous treatment to WIC participant Offense: □ 1st □ 2nd □ 3rd □ 4th □ No action: unsubstantiated or unintentional □ Written notice; and □ Training: □ offered or □ mandatory □ CAP Required □ 1-year disqualification Store failed to post “We Accept WIC” decal Offense: □ 1st □ 2nd □ 3rd □ 4th □ No action: unsubstantiated or unintentional □ Written notice; and □ Training: □ offered or □ mandatory □ CAP Required □ 1-year disqualification Program Compliance Form October 2025

Program Compliance Form State Staff Documentation Staff Name: Date Received: Claim Amount: Claim Letter Sent to Participant: Payment Received: Payment Schedule: Date Sent to Local Agency: Notes: Local Staff Documentation Staff Name: Date Received: Date Counseling Completed: Documentation in Chart: Date End of Cert./Notice of Ineligibility Provided (including Fair Hearing Information): Notes: Statement Date: □ Participant □ Retailer □ Staff Program Compliance Form October 2025

Reconstituted Amounts of Commonly Issued Formulas

October 2025 Reconstituted Amounts of Commonly Issued Formulas Partially Breastfeeding/Full Formula 0-3 months Substantially Breastfeeding 0-3 months Formula Type Powder Max allowed = 870 oz Concentrate Max allowed = 823 oz RTF Max allowed = 832 oz Powder 435 oz Concentrate 388 oz RTF 384 oz Can Size Reconstituted Amount Total Cans Can Size Reconstituted Amount Total Cans Bottle Size Total Bottles Total Cans Total Cans Total Bottles Similac Advance 12.4 oz 90 oz 9 13 oz 26 oz 31 32 oz 26 4 14 12 Similac Soy Isomil 12.4 oz 90 oz 9 13 oz 26 oz 31 32 oz 26 4 14 12 Similac Sensitive 12 oz 90 oz 9 13 oz 26 oz 31 32 oz 26 4 14 12 Similac Total Comfort 12.6 oz 90 oz 9 ------- ----------------- -------- -------- ---------------- 4 ----------------- --------- Enfamil AR 12.9 oz 91 oz 9 -------- ----------------- -------- -------- ---------------- 4 ----------------- -------- Alimentum 12.1 oz 87 oz 10 -------- ------------------ -------- 32 oz 26 5 ----------------- 12 Alfamino 14.1 oz 94 oz 9 -------- ------------------ -------- -------- ----------------- 4 ----------------- --------- Nutramigen Enflora LGG 12.6 oz 87 oz 10 -------- ------------------ -------- -------- ----------------- 5 ----------------- --------- Neosure 13.1 oz 87 oz 10 -------- ------------------ -------- 32 oz 26 5 ----------------- 12 EnfaCare 13.6 oz 87 oz 10 -------- ------------------ -------- 32 oz 26 5 ----------------- 12

Pregestimil 16 oz 112 oz 8* -------- ------------------ -------- -------- ----------------- 3 ----------------- --------- PurAmino 14.1 oz 98 oz 9* -------- ------------------ -------- -------- ----------------- 4 ----------------- --------- EleCare 14.1 oz 95 oz 9 -------- ------------------ -------- -------- ----------------- 4 ----------------- --------- Neocate Infant DHA & ARA 14.1oz 97 oz 9* -------- ------------------ -------- -------- ----------------- 5 ----------------- --------- *rounding provision used due to can size *rounding provision used due to can size

Partially Breastfeeding/Full Formula 4-5 months Substantially Breastfeeding 4-5 months Formula Type Powder Max allowed = 960 oz Concentrate Max allowed = 896 oz RTF Max allowed = 913 oz Powder Max = 522 oz Concentrate Max = 460 oz RTF Max = 474 oz Can Size Reconstituted Amount Total Cans Can Size Reconstituted Amount Total Cans Bottle Size Total Bottles Total Cans Total Cans Total Bottles Similac Advance 12.4 oz 90 oz 10 13 oz 26 oz 34 32 oz 28 5 17 14 Similac Soy Isomil 12.4 oz 90 oz 10 13 oz 26 oz 34 32 oz 28 5 17 14 Similac Sensitive 12 oz 90 oz 10 13 oz 26 oz 34 32 oz 28 5 17 14 Similac Total Comfort 12.6 oz 90 oz 10 ------- ----------------- -------- -------- ---------------- 5 -------------------- 14 Enfamil AR 12.9 oz 91 oz 10 -------- ------------------ -------- --------- ---------------- 5 ------------------- ----------------- Alimentum 12.1 oz 87 oz 11 -------- ------------------ -------- 32 oz 28 6 -------------------- 14 Alfamino 14.1 oz 94 oz 10 -------- ----------------- -------- -------- ----------------- 5 ------------------- ----------------- Nutramigen Enflora LGG 12.6 oz 87 oz 11 -------- ------------------ -------- -------- ----------------- 6 -------------------- ----------------- Neosure 13.1 oz 87 oz 11 -------- ------------------ -------- 32 oz 28 6 -------------------- 14 EnfaCare 13.6oz 87 oz 11 -------- ------------------ -------- 32 oz 28 6 -------------------- 14 Pregestimil 16 oz 112 oz 8 -------- ------------------ -------- -------- ----------------- 4 -------------------- ----------------- PurAmino 14.1 oz 98 oz 10* -------- ------------------ -------- -------- ----------------- 5 -------------------- ----------------- EleCare 14.1 oz 95 oz 10 -------- ------------------ -------- -------- ----------------- 5 -------------------- ----------------- Neocate Infant DHA & ARA 14.1 oz 97 oz 10* -------- ------------------ -------- -------- ----------------- 6 --------------------- -----------------

Reconstituted Amounts of Commonly Issued Formulas

October 2025 Partially Breastfeeding/Full Formula 6-11 months* Substantially Breastfeeding 6-11 months* Formula Type Powder Max allowed = 696 oz Concentrate Max allowed = 630 oz RTF Max allowed = 643 oz Powder Max = 384 oz Concentrate Max = 315 oz RTF Max = 338 oz Can Size Reconstituted Amount Total Cans Can Size Reconstituted Amount Total Cans Bottle Size Total Bottles Total Cans Total Cans Total Bottles Similac Advance 12.4 oz 90 oz 7 13 oz 26 oz 24 32 oz 20 4 12 10 Similac Soy Isomil 12.4 oz 90 oz 7 13 oz 26 oz 24 32 oz 20 4 12 10 Similac Sensitive 12 oz 90 oz 7 13oz 26oz 24 32 oz 20 4 12 10 Similac Total Comfort 12.6 oz 90 oz 7 ------- ----------------- -------- -------- ---------------- 4 -------------------- ------------------- Enfamil AR 12.9 oz 91 oz 7 -------- ------------------ --------- --------- ---------------- 4 ------------------- ------------------ Alimentum 12.1 oz 87 oz 8 -------- ------------------ -------- 32 oz 20 4 -------------------- ------------------- Alfamino 14.1 oz 94 oz 7 -------- ------------------ -------- -------- ----------------- 4 -------------------- -------------------- Nutramigen Enflora LGG 12.6 oz 87 oz 8 -------- ------------------ -------- -------- ----------------- 4 -------------------- ------------------- Neosure 13.1 oz 87 oz 8 -------- ------------------ -------- 32 oz 20 4 -------------------- 10 EnfaCare 13.6 oz 87 oz 8 -------- ------------------ -------- 32 oz 20 4 -------------------- 10 Pregestimil 16 oz 112 oz 6 -------- ------------------ -------- -------- ----------------- 3 -------------------- ------------------- PurAmino 14.1 oz 98 oz 7 -------- ------------------ -------- -------- ----------------- 7 -------------------- ------------------- EleCare 14.1 oz 95 oz 7 -------- ------------------ -------- -------- ----------------- 4 -------------------- ------------------- Neocate Infant DHA & ARA 14.1 oz 97 oz 7 -------- ------------------ -------- -------- ----------------- 4 -------------------- ------------------- *When a formula is prescribed and the medical provider does not allow WIC supplemental foods, the formula amount is the same as the amounts in the 4–5-month tables. Children Aged 1-5 and Women Formula Type Powder Max allowed = 910 oz Concentrate Max allowed = 910 oz RTF Max allowed = 910 oz Can Size Reconstituted Amount Total Cans Can Size Reconstituted Amount Total Cans Bottle Size Total Bottles Similac Advance 12.4 oz 90 oz 10 13 oz 26 oz 35 32 oz 28 Similac Soy Isomil 12.4 oz 90 oz 10 13 oz 26 oz 35 32 oz 28 Similac Sensitive 12 oz 90 oz 10 13 oz 26 oz 35 32 oz 28 Similac Total Comfort 12.6 oz 90 oz 10 -------- ----------------- -------- -------- --------------- Enfamil AR 12.9 oz 91 oz 10 -------- ------------------- --------- --------- --------------- Alimentum 12.1 oz 87 oz 10 -------- ------------------ -------- 32 oz 28 Alfamino Junior 14.1 oz 62 oz 14 -------- ------------------ ------- -------- ----------------- Nutramigen Toddler 12.6 oz 85 oz 10 -------- ------------------ -------- -------- ----------------- Pregestimil 16 oz 112 oz 8 -------- ------------------ -------- -------- ----------------- EleCare 14.1 oz 95 oz 9 -------- ------------------ -------- -------- ----------------- PurAmino Toddler 14.1 oz 66 oz 13 -------- ------------------ -------- -------- ----------------- Pediasure w/ or w/o Fiber --------- ------------------ --------- -------- ------------------ -------- 8 oz 113 Ensure --------- ------------------ --------- -------- ------------------ -------- 8 oz 113 Neocate Junior 14.1 oz 61 oz 14 -------- ------------------ -------- -------- ----------------- EleCare Junior 14.1 oz 62 oz 14 -------- ------------------ -------- -------- ----------------- Kate Farms Pediatric Std 1.2 --------- ------------------ -------- -------- ------------------ -------- 8.45oz 107 Kate Farms Standard 1.0 --------- ------------------ -------- -------- ------------------ -------- 11oz 82

Release of Information

The information is to be released from (identify name/location):

Healthcare Provider: _____________________________________________________

WIC Program: __________________________________________________________

Childcare Provider (including Head Start/Early Head Start):

______________________________________________________________________ Other: _________________________________________________________________ The information may to be provided to (identify name/location): Healthcare Provider: _____________________________________________________

WIC Program: __________________________________________________________

Childcare Provider (including Head Start/Early Head Start):

______________________________________________________________________

Other: _________________________________________________________________

The information that may be released from my records i ncludes (i.e., the purpose):

Any information from the record(s) that is requested by the receiving provider/program in the scope of their care and/or services of the participant(s) listed.

Only information related to: _______________________________________________ __________________________________________ ______ Completing this release is voluntary and will not impact your eligibility for WIC or any other program/entity identified on this form. I authorize the release of information for:

Participant(s)/Patient(s) Name(s): ___________________________________________

Release is valid until: □ 1 year from the date signed □ Other date (specify): _____________ This information is to be released for a specific purpose only and may not be used by the recipient for any other reason. This information may not be shared with a third party. I understand that I may revoke this authorization in writing at any time; except for information that may have already been shared. If this authorization has not been revoked, it will terminate one year from the date it was signed. Participant/Parent/Guardian/Authorized Rep Signature Date This institution is an equal opportunity provider. October 2025

Request for Hire

_______________________________________________________________________________ Complete and submit this form and supporting documentation to the State Office when considering hiring a position for which qualifications need review and approval. Local Agency: ________________________ Director: ________________ Date: __________________ Applicant Name:______________________ Position for Review □ Registered Dietitian (RD) – please submit licensure and/or Commission on Dietetic Registration (CDR) card. □ Competent Professional Authority (CPA) – please submit proof of qualification - MD, DO, PA, NP, RN, DTR: submit licensure and/or transcripts - Other degreed professionals: submit transcripts □ Breastfeeding Peer Counselor (BFPC)- complete the following: 1. Does the applicant have any professional certifications or credentials (i.e. nurse, nutritionist, lactation consultant/counselor)? □ Yes □ No 2. Does the applicant have experience with breastfeeding? □ Yes □ No How long? __________ 3. Does the applicant fit the model of a “peer” (i.e. age, demographics, and cultural background?) □ Yes □ No Please describe: __________________________________________________________________ State Agency Use Only Date Received: _________________ State Staff Member/Role: ________________________ □ Approved □ Denied □ Need Additional Information (specify): ________________________ Request for Hire October 2025

0 1. https://www.ecfr.gov/current/title-7/subtitle-B/chapter-II/subchapter-A/part-246 2. https://www.ecfr.gov/current/title-7/subtitle-B/chapter-II/subchapter-A/part-246 3. https://www.ecfr.gov/current/title-7/subtitle-B/chapter-II/subchapter-A/part-246 4. https://www.ecfr.gov/current/title-7/subtitle-B/chapter-II/subchapter-A/part-246

MONTANA WIC PROGRAM COOP Montana Department of Health and Human Services Women, Infants, and Children Program

Continuity of Operations Plan 2025

1 This page is intentionally left blank.

2 FOREWORD The Montana (MT) Special Supplemental Nutrition Program for Women, Infants, and Children (WIC), a program of the MT Department of Public Health and Human Services (DPHHS) has adopted this Continuity of Operations Plan (COOP) to ensure the capability to support employees, participants, local agencies, vendors, and other impacted parties during emergencies. Key objectives accomplished by the adoption of this COOP include: • Minimize disruption to normal WIC services. • Mitigate the extent of disruptive events and damage. • Minimize fiscal impacts of disruptive events to the state, local agencies, and participants. • Prepare personnel to implement emergency procedures. • Establish an alternate method to continue service delivery. • Provide for the rapid and efficient restoration of services. This COOP presents a continuity strategy intended to assure the resilience and operational capacity of MT WIC.

3 Contents Chapter 1: Introduction........................................................................................................................................................... 4 WIC Program Overview....................................................................................................................................................... 4 Chapter 2: Operational Disruptions ........................................................................................................................................ 5 Natural Disasters ................................................................................................................................................................. 5 Human Pandemic ................................................................................................................................................................ 5 Biological ............................................................................................................................................................................. 5 Infant Formula Recalls......................................................................................................................................................... 5 Chapter 3: WIC’s Role.............................................................................................................................................................. 6 WIC During a Disaster or Infant Formula Recall.................................................................................................................. 6 Chapter 4: WIC Operations ..................................................................................................................................................... 7 Mission Essential Workforce ............................................................................................................................................... 7 Mission Essential Workforce ............................................................................................................................................... 8 Essential Systems and Software Applications ................................................................................................................... 10 Alternative Worksites........................................................................................................................................................ 11 Chapter 5: Incident Management ......................................................................................................................................... 12 COOP Activation................................................................................................................................................................ 12 Incident Management Team ............................................................................................................................................. 12 Incident Communication................................................................................................................................................... 12 Personnel Safety and Accountability................................................................................................................................. 13 Chapter 6: Recovery and Reconstruction.............................................................................................................................. 13 Chapter 7: COOP Training...................................................................................................................................................... 13 Chapter 8: Plan Administration and Maintenance................................................................................................................ 14 8.1 Maintenance ............................................................................................................................................................... 14 8.2 Records and Reports ................................................................................................................................................... 14 Appendix A ............................................................................................................................................................................ 15 State WIC Staff Contact Information ................................................................................................................................. 15

4 Montana WIC Program Continuity of Operations Plan Chapter 1: Introduction WIC Program Overview WIC provides supplemental nutritious foods, nutrition education, breastfeeding promotion and support, and referrals to health and other social services for low-income pregnant, breastfeeding, and postpartum women, and to infants and children up to age five who are found to be at nutritional risk. The United States Department of Agriculture’s (USDA) Food and Nutrition Service (FNS) administers the WIC Program at the Federal level. WIC is not an entitlement program, i.e., Congress does not set aside funds to allow every eligible individual to participate in the program. Instead, Congress annually authorizes a specific amount of funding for program operations. Distribution of funds to state agencies like the MT DHHS occurs via a federal grant. FNS provides these funds to MT WIC to pay for WIC foods redeemed via electronic benefit transfer (EBT) cards, nutrition education, breastfeeding promotion and support, and administrative costs. Thirty-four (34) lead agencies, granted funds from the MT WIC Program, provide EBT cards to participants. The cards allow participants to purchase foods, specifically chosen to improve or maintain their nutritional health at critical periods of growth and development, at over 300 authorized vendors. Nationally, the WIC Program operates in every state, the District of Columbia, five Territories, and 34 Indian Tribal Organizations (ITOs). These agencies make program services available through an estimated 1,800 local agencies and 10,000 clinic sites.

5 Chapter 2: Operational Disruptions Operational disruptions include any wide-scale interruption to normal state WIC operations lasting for an extended period. Disruptions may include, but are not limited to, disasters, emergencies, and infant formula recalls. For the purposes of this COOP, a disaster or emergency is defined as a sudden, calamitous event that seriously disrupts the functioning of a community or society and causes human, material, and economic or environmental losses that exceed the community’s or society’s ability to cope using its own resources. Though often caused by nature, disasters can have human origins. Recalls are defined as any infant formula manufacturer choosing to remove or correct a distributed product for any reason and under any circumstance. Natural Disasters Natural disasters take different forms, such as a tornado, flood, fire, etc. A natural disaster has the potential to disrupt WIC operations and cause the relocation of WIC participants. Regardless of the disaster, MT WIC state and local agencies are expected to take reasonable measures to continue providing benefits to participants. The next chapter of this guide includes WIC program flexibilities regarding WIC operations for participants and/or newly eligible applicants. Human Pandemic During a pandemic event, like COVID-19, the key public health intervention to slow the spread of the disease may be social distancing. Schools and day care centers may be closed for extended periods of time, leaving many parents absent from work to care for their children. MT WIC may not be able to certify applicants for WIC at local WIC clinics due to restrictions on social gathering and will need to operate under alternate procedures. In addition, staff may face an increased workload as many state, local, and clinic employees and their families may also be impacted by the pandemic and unable to work. Biological Bioterrorism is the intentional release or dissemination of biological agents. These agents are bacteria, viruses, or toxins, and may be in a naturally occurring or manmade. Since the response to a biological disaster will be coordinated at a higher level than the WIC Program, state WIC staff will consult with the rest of DHHS on what, if any, biological procedures should be followed. In such situations, external agencies, like the Centers for Disease Control and Prevention (CDC), will focus on the identification and containment of the outbreak. Infant Formula Recalls An infant formula recall is defined as any suspension of the sale, distribution, and/or production of infant formula, usually voluntarily, by the manufacturer to protect the public’s health. Recalls may also be issued by the Food and Drug Administration (FDA). Recalls vary in scope and impact and should be evaluated individually for scope, potential impact, and remediation.

6 1. https://www.ecfr.gov/current/title-7/subtitle-B/chapter-II/subchapter-A/part-246 2. https://www.ecfr.gov/current/title-7/subtitle-B/chapter-II/subchapter-A/part-246 3. https://www.ecfr.gov/current/title-7/subtitle-B/chapter-II/subchapter-A/part-246 4. https://www.ecfr.gov/current/title-7/subtitle-B/chapter-II/subchapter-A/part-246 Chapter 3: WIC’s Role WIC During a Disaster or Infant Formula Recall An immediate and critical component for disaster or recall response teams is ensuring access to nutrition assistance for disaster survivors. USDA Foods and the Disaster Supplemental Nutrition Assistance Program (D-SNAP) are the primary methods FNS uses to respond to the nutrition needs of disaster survivors. Unlike USDA Foods and D-SNAP, WIC’s role in responding to disasters is minimal, as WIC is neither designed nor funded to meet the basic nutritional needs of disaster survivors not otherwise eligible for WIC benefits. Since there is no additional funding designated for WIC disaster relief, MT WIC must operate within its current program context and funding level even in disaster circumstances. However, there are many ways state WIC personnel can contribute to disaster relief efforts by minimizing disruptions to WIC operations and ensuring that eligible participants continue receiving benefits. WIC regulations provide flexibility regarding physical presence, certification periods, and mailing food instruments and/or issuing EBT cards, including: • Persons with a serious illness that may be exacerbated by coming into the WIC clinic may be exempt from the physical presence requirement (this would also apply if applicants/family members are under a voluntary quarantine)1 . • MT WIC may extend the certification period for breastfeeding women, infants, and children, up to 30 days, to accommodate difficulty in scheduling appointments2 . • MT WIC may issue electronic benefits to persons not scheduled for nutrition education or a second or subsequent certification3. • When WIC participants are unable to use their food instruments because they or another family member are under quarantine (voluntary or involuntary), they have the option to designate a proxy to redeem WIC benefits on their behalf4. During a disaster, MT WIC works to maintain regular benefit delivery to participants. State WIC staff may also focus on coordinating program outreach to potentially eligible individuals. Some individuals may be newly income eligible if their employment was affected by the disaster or if they now receive D-SNAP. Receiving D­ SNAP confers adjunctive income eligibility for WIC. To help communities prepare for disasters, WIC local agency staff can educate participants on food preparation and food safety concerns during disaster conditions as part of routine nutrition education services. Formula recalls necessitate a robust and immediate WIC response. WIC is designed and funded to meet the basic nutritional needs of infants and access to infant formula is essential. During a formula recall MT WIC works to ensure the uninterrupted delivery of infant formula benefits to participants. State staff focuses on identifying alternatives, coordinating with local agencies and vendors, and working with FNS on waivers and fiscal operations

7 Chapter 4: WIC Operations In the event of a disaster declaration or infant formula recall by national or state authorities, product manufactures, or others in a position of authority, the State WIC Director will initiate this COOP and its incorporated or referenced policies and procedures immediately. Mission Essential Workforce The following staff are essential to support WIC operations or are assigned a critical response role during a disaster or recall. In the event of a disaster or other operational disruption, staff will be contacted according to the SA communications plan in Appendix B. State WIC Director Assistant Director/Nutrition Coordinator Public Health Nutritionist I- Breastfeeding Coordintaor Public Health Nutritionist II Vendor Coordinator Lead Vendor Program Specialist Outreach Coordinator QA Analyst 2 QA Analyst 1 IT Systems Lead Figure 1

8 Mission Essential Workforce To maintain essential WIC operations, each key role is staffed by a member of the MT WIC program. The order of succession (figure 1) should be used in all instances of a disaster or formula recall. The QA Analyst, IT Systems Lead, Vendor Coordinator, Assistant Director/Nutrition Coordinator and Outreach Coordinator serve in support roles for the Director and other staff. If a staff member is incapacitated, or otherwise unable to fulfill their duties, proceed to the next individual in the chain. Contact information for all individuals can be found in Appendix A. WIC Director Alternate 1: Assistant Director/Nutrition Coordinator Alternate 2: Vendor Coordinator Essential tasks to perform: • Lead response activities with FNS, DPHHS, local agencies (LA), vendors, and others as required. • Create guidance for LA’s and state staff. • Oversee internal and external communication. • Lead situational briefings for LA’s and state staff. • Submit required FNS waivers. • Financial Management Authority to be delegated: • Guidance creation: Nutrition Coordinator • Waiver completion and submission: Vendor Coordinator • Financial Management: WIC Budget Analyst Vendor Coordinator Lead Alternate 1: Assistant Director/Nutrition Coordinator Alternate 2: Vendor Program Specialist Essential tasks to perform: • Create and provide communication with local vendors • Create guidance for LA’s and state staff on vendor system changes • Assist WIC Director on FNS communications • Assist WIC Director on FNS waivers. Authority to be delegated: • Communication to LA’s to other team members • Communication to local vendors to other team members Assistant Director/Nutrition Coordinator Alternate 1: WIC Director Alternate 2: Public Health Nutritionist I, Breastfeeding Coordinator Essential tasks to perform: • Provide guidance for LA’s • Coordinate Nutrition Services Team activities • Assist WIC Director on program duties Authority to be delegated: • Communication to LA’s to other team members

9 Public Health Nutritionist I- Breastfeeding Coordinator Alternate 1: Assistant Director/Nutrition Coordinator Alternate 2: Public Health Nutritionist II Essential tasks to perform: • Manage the program email MONTANAWICPROGRAM@MT.GOV • Create and provide guidance to LA’s regarding Breastfeeding services • Assist Nutrition Coordinator Lead with nutrition services activities • Assist with clinic coverage • Assist with WIC help desk Authority to be delegated: • NA Public Health Nutritionist II Alternate 1: Vendor Coordinator Alternate 2: Assistant Director/Nutrition Coordinator Essential tasks to perform: • Manage the program UPC email WICUPC@MT.GOV • Provide assistance to the Nutrition Coordinator Lead with nutrition activities • Assist Vendor Coordinator Lead with vendor activities • Assist with clinic coverage • Assist with WIC help desk Authority to be delegated: • NA Outreach Coordinator Alternate 1: Assistant Director/Nutrition Coordinator Alternate 2: Public Health Nutritionist II Essential tasks to perform: • Create and provide communication for WIC families utilizing WIC’s Marketing contractor o Messaging through WIC messaging platform o Social media posting • Communicate with staff to manage and update the WIC Website Authority to be delegated: • Posting information to the DPHHS WIC webpage • Posting information to DPHHS social media Vendor Program Specialist Alternate 1: Vendor Coordinator Alternate 2: Public Health Nutritionist II Essential tasks to perform: • Duties outlined by Vendor Coordinator Lead • Create and provide guidance to Farmer’s Market Nutrition farmers Authority to be delegated: • NA

10 IT Systems Lead Alternate 1: QA Analyst Alternate 2: BSO Bureau Chief Essential tasks to perform: • Develop and communicate with IT contacts • Develop and communicate with LA staff • Provide updates to BSO Bureau Chief and WIC Director • Assist WIC director on program duties • Assist WIC QA Analyst as needed Authority to be delegated: • Communication to IT contacts • Communication to LA staff QA Analyst 1 Alternate 1: WIC IT Systems Lead Alternate 2: QA Analyst 2 Essential tasks to perform: • Provide support to LA staff via WIC Help Desk • Assist WIC IT Systems Lead with program activities Authority to be delegated: • NA QA Analyst 2 Alternate 1: WIC IT Systems Lead Alternate 2: QA Analyst 1 Essential tasks to perform: • Provide support to LA staff via WIC Help Desk • Assist WIC IT Systems Lead with program activities Authority to be delegated: • NA Essential Systems and Software Applications MT WIC relies heavily on variety of technology systems. Participant certification or recertification, benefit issuance and redemption, and more rely on technology. These systems may be inoperable or inaccessible during a disaster, emergency, or recall. Hardware and software applications must be documented to assist recovery operations. Essential Hardware Equipment Description Manufacturer Model No. Serial No. Vendor/Support Contact Info Director’s laptop Dell N/A F0M68C3 DPHHS Director’s cell phone iPhone MT622LL/A F2LXH94JKPHK DPHHS, FirstNet Director’s desk phone Avaya 9611GD02B 16N5201079G1 DPHHS

11 Application and Software Inventory Manufacturer/Vendor Application Name Version # Application Interfaces/Dependencies CDP SWEB-MIS 3.3.0.1 Healthy Together WIC Portal JPMA WIC Shopper App 1.6 Solutran EBT Processor 3.45D.A IT Essential Records and Data Record Type Data Type Offsite Backup Backup Frequency Participant Records Journey File None N/A Authorized Vendor List Journey File DHHS Network Server – Nutrin FNS-FDP Annually IT Contacts Hardware or Application Vendor Name Contact Email Contact Phone DPHHS Laptops, phones, and applications SITSD Login - Montana (servicenowservices.com) 444-9500 SWEB-MIS CDP- Barry Burris Barry Burris barry.burris@sugpmo.com 580-272-2503 Ext 62572 EBT Solutran Samatha Bailey sbailey@solutran.com 763-519-7214 Teletask Teletask Brian Rees Brian@teletask.com 888-484-9911 Ext 109 WIC Shopper App JPMA Wicshopper.support@jpma.com 303-232-3700 WIC App Twenty Labs Healthy Together Jason Valadez jvaladez@twenty.co Alternative Worksites An event like a pandemic, fire, or tornado may render state offices inaccessible or unusable. Such an event necessitates the transfer of operations and relocation of personnel to an alternate worksite (AWS). The WIC Director, or their designee, is responsible for determining if the facility is safe to access and equipment suitable for use. Directions from DPHHS leadership, or their designees, may impact AWS decisions. WIC staff must be prepared to transfer operations to an alternate or backup worksite. WIC requires an AWS that supports timely activation with limited preparation efforts. An AWS could be an alternative state office site, a local agency, a disaster response organization site, working from home, or another site as needed. As events progress, the AWS may change. All decisions regarding AWS will be communicated by the WIC Director or their designee. Equipment and Supplies Needed for AWS

12 Laptop and charger Keyboard and mouse Work cell phone and charger Headphones/headset Desk or table Chair General office supplies VPN and Internet Access Mobile Hotspot Vital record storage (network access, flash drives, etc.) Chapter 5: Incident Management Most disaster and recall events are of short duration with limited impact on WIC. However, significant events may require the activation of this COOP. The WIC Director will continue operating using the normal organizational structure until, and unless, an alternate command and control structure is implemented by DHHS or its designee. COOP Activation The WIC Director or their designee are authorized to active this COOP in response to a disaster, emergency, or significant formula recall. Incident Management Team The Incident Management Team (IMT) concept is used to coordinate the response to an event that disrupts normal operations. The members of the IMT will be selected from WIC staff members based upon their roles and technical expertise. MT WIC will utilize its normal organizational structure to manage the response for short-term disaster or recall events. Complex or long-term events or recalls require the IMT to convene and coordinate on response efforts. Core members of the WIC IMT include: • State WIC Director • Vendor Coordinator • Assistant Director/Nutrition Coordinator • Breastfeeding Coordinator • Outreach Coordinator • WIC IT: QA Analysts 1 & 2 and IT System Lead Additional IMT members will be incorporated as needed based on the incident, staffing levels, and technical expertise. Incident Communication The WIC Director is responsible for coordinating information during an emergency or recall. WIC internal communications procedures utilize a combination of phone, text, and email to communicate with staff. The crisis communications plan addresses the following: • Staff notification and communication procedures o WIC Director responsible • Coordination with LA’s o Nutrition Coordinator responsible

13 • Coordination with vendors o Vendor Coordinator Lead responsible • Public information o Outreach Coordinator responsible with DPHHS PIO approval • Media relations via the DPHHS Public Information Officer (PIO) Personnel Safety and Accountability A continuity event can affect the health and safety of MT WIC staff. When a disruptive event occurs, personnel may be working in the office, remotely, or traveling outside of the area. The WIC Director must account for all employees during and after the occurrence of a continuity event. The emergency notification process will involve documenting the employee’s location, their health and safety status, and availability to report for work. The WIC Director will use a dedicated telephone number to aid in monitoring personnel status. Staff members will use the number to report their status and receive instructions and assignments. Personnel assigned to monitor the phone will maintain a log of staff contacts and document the status of each employee. A digital emergency contact list for personnel is maintained separately in Workday. Each staff member should review and update emergency contact information annually. Chapter 6: Recovery and Reconstruction Post-incident recovery involves evaluating the status of WIC resources following a disruptive incident and reorganizing to maintain operational capacity. Reconstitution is the process of resuming normal operations at the primary work site, AWS, or temporary/permanent replacement facility. Recovery and reconstitution activities will be implemented to restore the operational capacity of WIC. The organization will be prepared to support recovery on two levels. The first level, continuity of operations, involves the human and physical resources necessary to provide services to local agencies. The second level, disaster recovery, involves the recovery of IT equipment, systems, applications, and networks. The recovery process involves establishing and prioritizing short-term and long-term objectives. Examples of short-term recovery objectives include: • Provide for the needs and well-being of WIC staff • Continue operations at the AWS • Restore essential systems and services • Recover data • Assess damages to the facility and assets • Communicate with stakeholders. Examples of long-term recovery objectives include: • Replace equipment • Recruit and hire permanent staff • Restoration of the primary PSAP facility • Establish long-term operations at an interim worksite(s) as needed Chapter 7: COOP Training WIC staff will review the COOP Plan annually.

14 Chapter 8: Plan Administration and Maintenance This COOP Plan contains sensitive information that is restricted from public access. Distribution of this COOP Plan is limited to essential personnel and authorized representatives of partner agencies. 8.1 Maintenance The MT WIC Director is responsible for assuring that this COOP Plan is maintained. The COOP Plan will be reviewed and updated annually. 8.2 Records and Reports Records related to the activation of this COOP Plan must be maintained in compliance with applicable USDA­ FNS rules and regulations, state law, and MT DPHHS record-retention policies.

15 Appendix A State WIC Staff Contact Information Main Phone:1-800-433-4298

WIC Emails: Website • montanawicprogram@mt.gov • WIChelp@mt.gov • https://dphhs.mt.gov/ecfsd/wic/ NAME EMAIL OFFICE CELL Lacy Little- WIC Director lalittle@mt.gov 406-444-5923 406-594-5984 Kevin Moore- Vendor Coordinator Lead Kevin.moore@mt.gov 406-444-5530 Aimee Duncan- Assistant Director/Nutrition Coordinator Aimee.duncan@mt.gov 406-444-0909 406-594-5981 Lori Stenson- Public Health Nutritionist II Lori.Stenson@mt.gov 406-444-2740 406-439-5773 Nicole Bulik- Breastfeeding Coordintaor nicole.bulik@mt.gov 406-439-5592 406-439-5592 Kyra Clayton- Outreach Coordintaor Kyra.Clayton@mt.gov 406-444-5285 Bailey Menager- Vendor and Farmer’s Market Coordintaor Bailey.Menager@mt.gov 406-444-2841 Andrew McKeever- IT Systems Lead Andrew.mckeever@mt.gov 406-444-2739 Chelsea Giguere- QA Analyst Chelsea.giguere2@mt.gov 406-444-7015 Vacant- QA Analyst Vacant 406-444-3394

Tribal Eligibility Statement I, , verify that my family income does not exceed the current maximum income eligibility guidelines as explained to me by the Montana WIC staff. I attest that if I knowingly falsify information in order to receive benefits, I am subject to disqualification from the Montana WIC Program. Participant’s Signature _______________________ Date __________________ WIC Staff Signature__________________________ Date ______________ ____ This form must be signed and scanned into all household members’ files. USDA Nondiscrimination Statement 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/USDA-OASCR%20P-Complaint-Form-0508-0002­ 508-11-28-17Fax2Mail.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. Tribal Eligibility Statement October 2025

_______________________________________________ ___________________ Voter Registration Disclaimer Household ID Number: _______________ The National Voter Registration Act requires all participants to complete a voter registration disclaimer. Instructions: Please read and fill out this form. If you do not understand part of it, please ask for assistance. Would you like to register to vote? Yes

No Already Registered 1. Applying to register or declining to register to vote will not affect the amount of assistance that will be provided by this agency. 2. If you do not check either, it will be considered that you have decided not to register to vote at this time. 3. If you would like help in filling out the voter registration application form, staff will help you. The decision whether to seek or accept help is yours. You may fill out the registration form in private. 4. If you believe that someone interfered with your right to register or to decline to register to vote, your right to privacy in deciding whether to register or in applying to register to vote, or your right to choose your own political party, or other political preference, you may file a complaint with the county clerk and recorder. I have read and understand my voter’s registration rights for participation in the Montana WIC Program: Signature of Participant/Authorized Representative Date Thank you for taking the time to read/fill out this disclaimer. If you have any questions, please don’t hesitate to ask your local WIC staff, or call the state office at 1-800-433-4298. This institution is an equal opportunity provider. Voter Registration Disclaimer October 2025 SIGN

_____________________________________________________________________________________ _____________________________________________________________________________________ _____________________________________________________________________________________ ____________________________________________________________________________________ ____________________________ ____________________________ ___________ ___________ Montana WIC Affidavit Proof of ID/Income/Residency Scan into participant’s file. Staff Use this form when proof of ID, income (does not include zero income), or residency documentation does not exist or if using pending proof for income. Examples: 1. The person works for cash. a. Enter the self-reported household income and assess if it meets WIC Eligibility guidelines. b. Select “Statement of Income” for proof of income. 2. Documentation was destroyed in a house fire or natural disaster. 3. Participant is homeless. 4. Participant is a migrant. 5. Participant has ID and residency proofs but is pending income proof. 6. Other reasons may qualify on a case-to-case basis. Please contact State Office. Participant/Authorized Rep I verify I do not have proof of the following: Identification Residency Income o I work for cash and don’t receive documentation. o My income documentation was destroyed. o I am homeless. o I have no proof of income for some of the past 12 months. o Pending proof of income: household stated income $__________________ *If zero income, use the Zero Income Form. Please use the space below to explain why documentation is not provided. I, ______________________________________________ (Print Name: Participant/Authorized Rep) I attest that if I knowingly falsify information in order to receive benefits, I am subject to disqualification from the Montana WIC program. Proof of ID/Income/Residency Participant/Authorized Rep Signature WIC Staff Signature Date Date October 2025

Montana WIC Affidavit Proof of ID/Income/Residency Scan into participant’s file. USDA Nondiscrimination Statement 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. Proof of ID/Income/Residency October 2025

Declaración jurada del WIC de Montana Prueba de identificación/ingresos/residencia Personal Utilice este formulario cuando no exista una prueba de identificación, ingresos (no incluye cero ingresos) o documentación de residencia, o si utiliza una prueba pendiente de ingresos. Ejemplos: 1. La persona trabaja por dinero en efectivo. a. Introduzca los ingresos del hogar autoinformados y evalúe si cumplen con las pautas de elegibilidad del WIC. b. Seleccione “Declaración de ingresos” como prueba de ingresos. 2. La documentación se destruyó en un incendio doméstico o desastre natural. 3. El participante no tiene hogar. 4. El participante es migrante. 5. El participante tiene pruebas de identificación y residencia, pero tiene las pruebas de ingresos pendientes. 6. Otros motivos pueden calificar según el caso. Comuníquese con la Oficina Estatal. Participante/representante autorizado Confirmo que no tengo prueba de lo siguiente: ☐ Identificación ☐ Residencia ☐ Ingresos o Trabajo por dinero en efectivo y no recibo documentación. o Mi documentación de ingresos fue destruida. o Soy indigente. o No tengo prueba de ingresos para algunos de los últimos 12 meses. o Prueba de ingresos pendiente: ingresos declarados por el hogar $ * Si no tiene ingresos, use el formulario de cero ingresos. Utilice el espacio a continuación para explicar por qué no se proporciona documentación. Yo, (Nombre en letra de imprenta: participante/representante autorizado) Testifico que si falsifico información a sabiendas para recibir beneficios, estoy sujeto a la descalificación del programa WIC de Montana. Firma del participante/representante Fecha autorizado Firma del personal de WIC Fecha Escanee en el archivo del participante. Prueba de identificación/ingresos/residencia Octubre de 2025

Declaración jurada del WIC de Montana Prueba de identificación/ingresos/residencia Declaración de no discriminación del USDA De acuerdo con la ley federal de derechos civiles y las reglamentaciones y políticas de derechos civiles del Departamento de Agricultura de los EE. UU. (U.S. Department of Agriculture, USDA), esta institución tiene prohibido discriminar por motivos de raza, color, nacionalidad, sexo (incluida la identidad de género y orientación sexual), discapacidad, edad o represalias por actividades anteriores de derechos civiles. La información del programa puede estar disponible en otros idiomas que no sean inglés. Las personas con discapacidades que requieran medios alternativos de comunicación para obtener información del programa (p. ej., Braille, letra grande, cinta de audio, lenguaje estadounidense de señas), deben comunicarse con la agencia estatal o local responsable que administra el programa o con el Centro TARGET del USDA al (202) 720-2600 (voz y TTY) o comunicarse con el USDA a través del Servicio Federal de Retransmisión al (800) 877-8339. Para presentar una queja por discriminación en el programa, el denunciante debe completar un Formulario AD­ 3027, Formulario de queja por discriminación en el programa del USDA, que puede obtenerse en línea en: https://www.usda.gov/sites/default/files/documents/ad-3027.pdf, en cualquier oficina del USDA, llamando al (866) 632-9992 o escribiendo una carta dirigida al USDA. La carta debe contener el nombre, la dirección, el número de teléfono y una descripción escrita de la presunta acción discriminatoria con suficiente detalle para informar al Subsecretario de Derechos Civiles (Assistant Secretary for Civil Rights, ASCR) sobre la naturaleza y la fecha de una presunta violación de los derechos civiles. El formulario AD-3027 completado o la carta deben enviarse al 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. Prueba de identificación/ingresos/residencia Octubre de 2025

WIC Memorandum of Understanding Disclaimer This institution is an equal opportunity provider. October 2025 The Montana WIC Program has Memorandums of Understanding (MOUs), or agreements, with other entities which may include a provision to share participant information. The Rights and Responsibilities signed at each certification includes a statement that you acknowledge this. The following agreements are currently in place statewide: Immunizations Program: may share personally identifiable data for the purposes of outreach, referral, and data analysis to improve health outcomes of our participants and streamline services. Medicaid, SNAP and TANF: may share personally identifiable data for the purposes of outreach, referral, and data analysis to improve health outcomes of our participants and streamline eligibility, access and service delivery. Healthy Montana Families Program (HMF), also known as Maternal and Early Childhood Home Visiting (MECHV): may share personally identifiable data for the purposes of outreach, referral, and data analysis to improve health outcomes of our participants and streamline services. Pregnancy Risk Assessment Management System (PRAMS): may share personally identifiable data for the purposes of outreach and data analysis to improve health outcomes of our participants. Census Bureau: census and WIC data are matched annually for the purposes of outreach and data analysis to improve health outcomes of our participants. SNAP-Ed: Montana WIC and SNAP-Ed have an MOU that does not include sharing of personally identifiable data. The intent of this agreement is to outline our collaborative efforts to streamline and align nutrition education initiatives. Child and Adult Care Food Program (CACFP): Montana WIC and CACFP have an MOU that does not include sharing of personally identifiable data. The intent of this agreement is to ensure nutrition education materials developed and available by each program is made available for sharing. Your information may be shared only for the purposes described above and will not be shared with any third parties unless you provide written consent. Please let us know if you have any questions or concerns. If you would like your information to be shared with another program or provider, please request to complete a Release of Information.

Chelsea Giguere - QA Analyst Ph: 444-7015 Email: Chelsea.Giguere2@mt.gov Helpdesk: (800) 433-4298 x 1 wichelp@mt.gov Responsibilities: Primary Tester for SPIRIT and S3; help desk; Intake EBT/APL issues; receive and process access requests Nicole Bulik CLC- Public Health Nutritionist/Breastfeeding Coordinator Ph: 439-5592 Email: Nicole.Bulik@mt.gov Primary Responsibilities: Breastfeeding promotion; breast pump policies and guidance; Breastfeeding Peer Counselor Program oversight; local agency monitoring; technical assistance related to any breastfeeding, nutrition and/or clinic services. Kyra Clayton MA – Outreach & Quality Improvement Coordinator Ph: 444-4747 Email: Kyra.Clayton@mt.gov Primary Responsibilities: Outreach; project management; quality improvement; collaboration & coordination with partners; website updates; newsletters; other communications. Bailey Menager – Vendor & Farmer’s Market Nutrition Coordinator Ph: 444-2841 Email: Bailey.Menager@mt.gov Primary Responsibilities: Farmers Market Coordinator; retailer contract management; policy updates and implementation; retail compliance investigations; retailer stocking requirements; retailer complaints; FDP reporting. Lori Stenson – Public Health Nutritionist & Vendor Coordinator Ph: 444-2740 Email: Lori.Stenson@mt.gov Primary Responsibilities: Local agency monitoring; technical assistance for clinic services; policy updates and implementation; program integrity and outreach activities; formula orders; supplies ordering/inventory. Andrew McKeever – IT Systems Lead Ph: 444-2739 Email: Andrew.McKeever@mt.gov Helpdesk: (800) 433-4298 x 1 wichelp@mt.gov Responsibilities: SPIRIT system management; database management; data queries; helpdesk and testing oversight/back up; SPIRIT User Group member (ESC, STAC) Kevin Moore, MS- Vendor Lead Ph: 444-5530 Email: KMoore@mt.gov Primary Responsibilities: Vendor coordinator (outreach, training, technical assistance); retailer newsletter; peer group review and updates; retailer/LARC materials and training; policy updates and implementation; eWIC transaction research and resolution; program complaints & fraud detection. Aimee Duncan MS, RD, CLC – Assistant WIC Director- Nutrition Coordinator Ph: 444-0909 Email: Aimee.Duncan@mt.gov Primary Responsibilities: Nutrition policy updates; nutrition education resources & training; new employee approvals; continuing education approval; monitoring; special formula order approval; SPIRIT User Group (CCWG); Nutrition Risk Codes/High Risk Criteria; food package review; Approved Product List (APL) updates; inventory control. WIC Program WIC State Director/Section Supervisor: Lacy Little, MPH, RD, CLC Ph: 444-5923 Email: Lalittle@mt.gov Business/Operations Support (BSO) Supervisor: Chris Delvaux, Bureau Chief Ph: 444-4746 Email: chris.delvaux@mt.gov Family & Community Health Bureau (FCHB) Jacqueline Isaly, Bureau Chief Ph: 444-4743 Email: jacqueline.isaly@mt.gov Early Childhood & Family Support Division (ECFSD) Tracy Moseman, Administrator Ph: 444-6676 Email: Tracy.moseman@mt.gov This Institution is an Equal Opportunity Provider Special Supplemental Nutrition Program for Women, Infants and Children (WIC) 1625 11th Ave., USF&G Building (Basement), PO Box 4210, Helena, MT 59620-4210 Toll Free: (800) 433-4298 Direct: (406) 444-5533 Fax: (406) 444-0239 Email: montanawicprogram@mt.gov DPHHS MONTANA Vacant - QA Analyst Ph: Email: Helpdesk: (800) 433-4298 x 1 wichelp@mt.gov Responsibilities: Tester for SPIRIT and S3; help desk; Intake EBT/APL issues; receive and process access requests

WIC Remote Registered Dietitian Scope of Services October 2025 WIC REMOTE REGISTERED DIETITIAN SCOPE OF SERVICES Purpose Each local agency providing WIC clinical services in the State of Montana must have a Registered Dietitian (RD) available to provide the services as outlined in this Scope of Services attachment. The RD must maintain their credentials and licensure in good standing with the Commission on Dietetic Registration and the State of Montana Department of Labor and Industry throughout their term of service with WIC. SERVICES TO BE PROVIDED 1. Complete all required WIC training, including the following, but not limited to: a. Management Information System (MIS) modules b. Civil rights (initial and annually thereafter) c. Review of Montana WIC Risk Codes (complete list) and High-Risk Code Referrals 2. Coordinate with local clinic staff on an acceptable schedule for WIC participants to be scheduled. a. Flexibility is essential to ensure participants may be scheduled at a time that accommodates them b. Services must be provided through a secure method. 3. Work with local agency staff on system of referral for participant services. 4. Provide assessment, counseling, education, and care plan for all referred participants. a. Follow-up schedule with RD is at the discretion of the RD and shall be documented in the care plan b. If the issue is resolved, the participant denies services, or the issue is beyond the scope of what the RD may intervene in, the RD may release the participant to low-risk follow up plan with clinic or refer out to another health professional c. If the RD is the only Competent Professional Authority (CPA) working with the local WIC clinic, all mandated CPA specific functions must be completed by the RD. 5. If the participant is already being followed by specialists, other healthcare providers or Nutritionists, the WIC RD (or clinic staff) may request a release to consult with the provider and ensure our services are supportive of their care plan. 6. Provide approval, denial, or other edits to the supplemental foods section on the WIC Prescription Form for participants designated in Food Package III when the Healthcare Provider checks the box to defer to the RD. a. This will be completed and returned to the clinic (by secure means) within 1 business day of request

WIC Remote Registered Dietitian Scope of Services October 2025 b. Review of chart, including growth, intake, assessment notes, medical history and diagnoses will be completed prior to completing this section of the form c. Consult with the participant or caretaker, or healthcare provider, is expected when assessing for food readiness in medically fragile circumstances 7. Provide consult, training, materials, and/or mentoring to clinic staff on nutrition topics as requested. This may be in the form of: a. Working through a chart review to ensure the clinic staff are supporting the High- Risk Care Plan appropriately. b. Ensuring clinic staff are making appropriate referrals related to their scope of practice; and/or c. Providing links or copies of reputable resources for information and education. 8. Documentation of all WIC contacts, or attempted contacts, will be completed and submitted directly into the MIS system, or provided to the local agency staff to input or scan in within 1 business day of contact. 9. RD shall follow up with all participants who miss their scheduled appointments at least once to reschedule. Documentation of contacts, or attempted to contacts, must be in the participant chart. 10. Act in the role of Nutrition Coordinator for the clinic and ensure all nutrition related training needs are met by staff if another RD is not already fulfilling this role within the local agency. 11. Lead the agency effort of development and implementation of the Nutrition & Breastfeeding Plans (role of the Nutrition Coordinator). LOCAL AGENCY WILL 1. Schedule participants determined to meet the high-risk criteria, or whom the CPA otherwise considers needing additional nutritional intervention. 2. Provide access to participant chart to review components relevant to the referral. 3. Provide guidance on WIC policy and program expectations. 4. Defer to RD on nutritional counseling outside of their scope of practice. 5. Consult with RD to ensure care plan is being followed as intended. 6. Ensure participants understand that RD services are free, available, and encouraged to meet the objectives of the program. 7. Assist RD in rescheduling appointments when missed a. May provide benefits monthly until RD referral is followed through, unless the RD is also covering essential CPA role. b. Participant may deny referral and continue schedule determined by the WIC CPA, with documentation. 8. Consult with RD on issues of health and nutrition to improve knowledge base, resources available, and care management with participants.

WIC System Access Request Last Name: First Name: Middle Name: DOB: C/P #: Phone Number: Email Address: **All Fields Must Be Completed** Submit completed form to MontanaWICProgram@mt.gov Additional Access: Employee Role (Aid, CPA, Etc.): New Position: □ No □ Yes □ SIS □ SOAR □ SWeb □ Tableau □ Teletask □ Time Study □ WICSmart □ Healthy Together □ Other: At the Following Locations: Access Termination to be Completed by Supervisor: Date of Termination: Reason for Termination: Remove all access: □ Yes □ No Employee transferring to another HHS position: □ Yes □ No Complete the following when only removing some access: Access to be removed: Employee Role: □ SIS □ SOAR □ SWeb □ Tableau □ Teletask □ Time Study □ WICSmart □ Healthy Together □ Other: At the Following Locations: State Office Use Only: Reason for Additional Access: State Nutritionist Signature: Date: WIC System Access Amendment FFY 2025-2026

WIC System Access Request Last Name: First Name: Middle Name: DOB: C/P #: Phone Number: Email Address: **All Fields Must Be Completed** Submit completed form to MontanaWICProgram@mt.gov Requires Access to: □ State E-Mail Address □ SWeb □ Teletask □ WICSmart □ SIS □ SOAR □ Tableau □ Time Study □ FOB □ Healthy Together □ Other: Role Request: Clinic: □ Aide* □ High Risk RN* □ RD* □ CPA* □ Breastfeeding Peer Counselor* □ FMNP Benefits Issuer* □ LARC □ WIC Director □ Breastfeeding Coordinator *Documentation of education/training must be provided to the State Office before these roles can be assigned. State Office: □ Epidemiologist □ Finance □ Nutrition □ State View □ Vendor Admin □ IT At the Following Agencies: □ Beaverhead □ Custer One Health □ Gallatin □ Northern Cheyenne □ Sanders □ Big Horn □ Dawson □ Glacier □ Park □ Silver Bow □ Blackfeet □ Deer Lodge □ Hill □ Pondera □ Teton □ Carter □ Fergus □ Lake □ Ravalli □ Toole □ Cascade □ Flathead □ Lewis and Clark □ Richland □ Valley □ Chouteau □ Fort Belknap □ Lincoln □ Riverstone □ CSKT □ Fort Peck □ Missoula □ Rocky Boy □ Other: State Office Use Only: Access Requested Above: □ Approved □ Denied Reason: State Nutritionist Signature: Date: IT Notes Only: WIC System Access Form FFY 2025-2026

Zero Income Statement I, ,verify that I have zero income. I do not have income from employment, unemployment, savings accounts, regular contributions from another person, child support, or other sources that meet WIC’s income requirements as explained to me by the Montana WIC staff. My housing is paid by: My food is paid by: ______ My utilities are paid by: ______ N/A- Foster Child I attest that if I knowingly falsify information in order to receive benefits, I am subject todisqualification from the Montana WIC Program. I was referred by WIC staff to apply for assistance through Medicaid, SNAP and/or TANF. Participant Signature:__________________________________ Date:_________________ WIC Staff Signature:___________________________________ Date:_________________ This form must be signed and scanned into all household members’ files. USDA Nondiscrimination Statement 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. Zero Income Statement October 2025 SIGN SIGN

Montana WIC Nutrition and Breastfeeding Services Plan October 1, 2022 – September 30, 2026

Table of Contents Introduction 3 Statewide Goals & Objectives 4 Local Agencies Alignment with State Nutrition and Breastfeeding Service Plan 14 Local Agency Nutrition and Breastfeeding Services Plan 14 Monitoring and Dissemination 19 References 20 Appendix 21

Introduction This Nutrition and Breastfeeding Services Plan (NBSP) was developed by the Montana WIC Program’s WIC Work Group (WWG) in conjunction with Yarrow LLC, a contracted public health consulting organization, from October 2021 to July 2022. The WWG included state WIC employees as well as representatives from various local agencies throughout the state who generally serve two-year terms. The WWG met three times over the course of the year to collaboratively create goals, objectives, and action plans based on the results of the 2021 WIC Needs Assessment and their knowledge from the field. The NBSP includes federally designated state responsibilities for nutrition and breastfeeding, as well as the highest priority needs that were identified by the Needs Assessment. Statewide goals and objectives are presented, and action plans for State and Local Agencies were developed to achieve these goals. An important element of the State NBSP is the alignment of all Local Agency action plans to the State NBSP. Going forward the Local Agency plans will align directly with the State NBSP to ensure that each Local Agency is working towards the same overarching goals as the State. In addition to the State NBSP, Montana is piloting a full Nutrition Services Standards (NSS) review. The results from this review will be used in conjunction with findings from the Needs Assessment to improve the quality of services provided by WIC locations across the State. The State NBSP was created to satisfy the federal requirement that every WIC local agency align a plan with their State Nutrition and Breastfeeding Services Plan.

Statewide Goals & Objectives The following goals were developed based on findings from the 2021 WIC Needs Assessment. These six goals encompass the areas within the Montana WIC Program that can be improved upon for the benefit of WIC staff, as well as current and future WIC Program participants. Priority Area 1: Increase Participation Goal: Increase the percent of the eligible infants and children participating in Montana WIC from 55.5% (2018) to 65.5% by 2026. Priority Area 2: Service Improvement and Expansion Goal: Increase access to the highest quality breastfeeding and nutrition services possible. Priority Area 3: Staffing Goal: Ensure all (100%) clinics are sufficiently staffed, according to the Local Agency Directors and State Office recommendations, across various positions. Priority Area 4: Cultural Adaptations for Communities of Color and Religious Groups Goal: Improvements are made towards equity and culturally appropriate service delivery for communities of black, indigenous, people of color (BIPOC), and religious groups across the state of Montana. Priority Area 5: Data Use and Quality Goal: Improve data quality and accuracy to enable data driven decision making for targeted service delivery. Priority Area 6: Funding Goal: Ensure that every Local Agency is within 5% of the funding formula compared to their requested budget by 2026.

Priority Area 1: Increase Participation Goal: Increase the percent of the eligible infants and children participating in Montana WIC from 55.5% (2018) to 65.5% by 2026. Rationale: Without question, participants are the most vital component of all WIC programs. However, in Montana and nationally, rates of women, infant, and children participation have been steadily declining over the past decade. Specifically, from 2016-2021, overall participation in the Montana WIC program decreased by 22%, with the largest drop among women (pregnant, breastfeeding, and postpartum), who saw a 32.9% decrease over the same period (WIC Part Count 2016-2020). Key elements to consider for increased program participation include recruitment and retention, utilization of provided resources, and redemption. In 2018, 48% of infants and children (under 5) in Montana were eligible for WIC services. Of that, 56% participated in WIC (WIC MT Elg Census 2013-2018). Likewise, in 2020, only 73% of certified WIC participants utilized benefits provided to them, down from 92% in 2018 and 90% in 2019. (MT WIC M-SPIRIT Benefit Pack Data 2021) Reaching those who are eligible and ensuring they continue to participate is difficult but necessary to realize the Program’s potential impact on the health and wellness of women, infants and children across Montana. Objectives: Objective 1: Recruitment - Agencies who either fall in the top 10 counties of “need” based on the Affirmative Action Plan (AAP) will increase the potentially eligible enrollment in each county by 5% by 2026. Strategy: Partnerships - Identify possible partners for recruitment efforts and establish appropriate level (State or Local) Memorandums of Understanding (MOUs) with each partner. Strategy: Referral Processes - Promote referral processes that include warm handoffs and WIC-related anthropometric and hematologic measures as applicable with clinical partners. Strategy: Tribal - Meet with representatives from each Tribal Nation in Montana to address recruitment and referral needs among Tribal communities. Strategy: Marketing - Promote WIC services through statewide campaigns and support of Local Agency outreach activities. Strategy: Novel Pilot Projects - Pilot at least one project to investigate the options for digitizing the WIC process, i.e., online application/screening tool, appointment scheduling, and/or participant portal and telehealth options.

Objective 2: Retention & Utilization - Increase the percent of certification months utilized from 73% in 2018 to 95% in 2026. Strategy: Understanding Retention - Complete qualitative research with participants regarding utilization, use technology to gather feedback on participation in the first year, and shopping experiences (auto text, etc.), and / or discussing store experience at appointments. Strategy: Best Practices for Retention – Implement best practices for participant retention. Note: Focus on children 1-5. Strategy: Best Practices for Utilization Outreach – Implement best practices for supporting participants that are under-utilizing benefits Strategy: Participant-centered Services - Resolve barriers to program participation with a focus on streamlining services to use participants’ time more effectively. Strategy: Remote Appointments - Maintain the option, when feasible, of remote appointments for clinics and families. Objective 3: Redemption - Improve food redemption rates from 49% in 2020 to 60% by 2026. Strategy: Promoting WIC Foods – Identify and make available educational materials to be used by Local Agencies to support participants in fully utilizing benefits. Strategy: Improve Store Experience - Identify and address common issues across stores that are contributing to a negative store experience. Strategy: Redemption Outreach - Increase the number of participating grocery stores and/or research options for alternative delivery methods (ex. mobile WIC stores or appointment vans), with an emphasis on rural areas and food deserts.

Priority Area 2: Service Improvement and Expansion Goal: Increase access to the highest quality breastfeeding and nutrition services possible. Rationale: Extending WIC program services to reach as many eligible women and children as possible is vital. By utilizing telehealth to provide remote services to participants in the far reaches of Montana and working to integrate WIC into clinical settings, local agencies are doing everything they can to expand WIC program services and capture those who are eligible for the program. but for a myriad of reasons, are not enrolled in WIC. WIC also aims to raise the caliber of breastfeeding and nutrition services that it provides its participants. For example, the Breastfeeding Peer Counselor Program provides invaluable support and education to breastfeeding women, but only 78% of WIC participants had access to this program in 2021. (WIC Staff Density 2021) Objectives: Objective 1: Increasing Breastfeeding Duration - Increase breastfeeding duration for 6 & 12 months of age by 2026. For 6 months, increase breastfeeding duration rates from 27% to 60%. For 12 months, increase from 14% to 18%. Strategy: Stigma Reduction - Support community activities to reduce stigma around breastfeeding. Strategy: Promoting Breastfeeding in the Workplace - Collaborate with the MT Breastfeeding Coalition and other statewide health organizations to promote and educate employers on “Break Time for Nursing Mothers” law. Objective 2: Coordinate and Collaborate with Partner Groups - Maintain partnerships with statewide coalitions, collaboratives, and professional organizations to ensure WIC services are aligned with statewide initiatives and best practices. Strategy: Food Security Coalitions - WIC’s participation with the MT Partnership to End Childhood Hunger (MT-PECH) and MT Food Security Council (FSC) are vital efforts that align programs and create innovative interventions to decrease hunger. WIC will continue to actively participate, align, and work toward shared goals with MT-PECH and the FSC. Strategy: Clinical Partnerships - Support the nationwide effort to strengthen the linkage between medical clinics (pediatric and perinatal) and WIC by fostering and maintaining a strong working relationship with the MT AAP and MT ACOG chapters, and other healthcare associations, including expansion of the pilot Nutrition Access Project (NAP) with MT AAP.

Strategy: MT Perinatal Mental Health Collaborative - Ensure that WIC aligns with state partners working on perinatal mental health and implements best practices around screening and referral for perinatal mental health within the WIC setting. Strategy: Social Determinants of Health - Continue to share information about WIC services and learn from other organizations about maternal and child health in all capacities to ensure that WIC continually updates and integrates best practices. Objective 3: Integration of WIC into Community Settings - By Fiscal Year 2026, the MT WIC program will have 4 WIC agencies participating in integration projects with healthcare providers and/or other interested community partners. Strategy: Nutrition Access Project & Innovative Technology Tools – Establish best practices for integrating WIC and/or creating screening, education, and referral to WIC within healthcare settings as identified through the Nutrition Access Project. Strategy: Learn – Compile ideas of WIC integration models used in other states in both healthcare and community settings. Objective 4: Promoting Breastfeeding Peer Counselor Programs - Increase the percent of women in WIC that have access to Breastfeeding Peer Counselor Programs from 75.6% to 85% by 2026. At least 2 Peer Counselors will be Tribally affiliated and provide services to their tribal nations (none at baseline 2022). Strategy: Fiscal Considerations - Increase funding for Breastfeeding Peer Counselor Programs to expand existing programs and establish new programs. Strategy: Tribal - Identify and engage with a WIC Tribal liaison who can initiate discussions around Breastfeeding Peer Counselor Programs among Tribal agencies. Strategy: Remote Appointments - Ensure adequate technology and equipment to enable remote Breastfeeding Peer Counselor Programs across clinics and/or agencies.

Priority Area 3: Staffing Goal: Ensure all (100%) clinics are sufficiently staffed, according to the Local Agency Directors and State Office recommendations, across various positions. Rationale: Even though WIC offers outstanding services, not having enough staff to provide these services is limiting to not only the organization, but also to the participants. In 2021, the average ratio of WIC staff to participants in Montana was 1:216, but this ratio changes depending on the role. For example, the highest staff to participant ratio was seen among Registered Dietitian Nutritionists (RDNs) at 1 RDN for every 1,151 participants. Furthermore, primary Montana WIC staff roles in local agencies, including CPAs, Aides, and RDNs, saw on average less than one full-time equivalent (FTE) for each position (WIC Staff Density 2021). Increasing these critical staff positions is beneficial for both employees and WIC program participants. When Local Agencies are understaffed, it leads to staff burnout and job dissatisfaction, while also limiting the products and resources the Local Agency can provide for its participants. Objectives: Objective 1: Increase CLCs & IBCLCs - 100% of WIC agencies and 75% of WIC clinics have a CLC or IBCLC by 2026. (Baseline: Feb 2022 is 67% of agencies and 58% of clinics have either a CLC or IBCLC.) Strategy: IBCLC Mentorship – Support local agencies to develop partnerships with local hospitals and organizations with existing IBCLCs for mentoring current CLCs to become IBCLCs. Strategy: CLC Training - Prioritize funding for CLC training, in-person or virtually. Objective 2: Identify and Support Appropriate Staffing Levels for CPAs & RDNs - By Fiscal Year 2026 the MT WIC will establish recommended staffing levels for CPAs and RDNs based on clinic size, rurality, Affirmative Action Indicators 1 , and other elements as deemed appropriate. Strategy: Establish Staffing Formulas - Establish an appropriate staffing ratio and share staffing level data and tools to address gaps, with each Local Agency, annually. Strategy: Alternative Staffing Models- Investigate alternative staffing models such as paraprofessional pathways to becoming a CPA, or state employment of RDNs. ______________________

1 Affirmative Action Indicators include: term births, preterm births, infants on Medicaid before age 1, food insecurity, adequate prenatal care, LBW, and teen births

Priority Area 4: Cultural Adaptations for Communities of Color and Religious Groups Goal: Improvements are made towards addressing health disparities by improving equitable access and culturally appropriate service delivery for communities of black, indigenous, people of color (BIPOC), and religious groups across the state of Montana. Rationale: Black, indigenous, and people of color (BIPOC) consistently experience greater rates of health disparities compared to their White counterparts across Montana. One way to mitigate this for Montana WIC’s BIPOC population is to ensure that WIC local agency staff are trained to provide culturally competent services. Another way is to provide BIPOC and religious minority groups access to culturally relevant nutrition education, foods, and traditional ways of knowing (WIC Needs Assessment 2021). Objectives: Objective 1: Learn and Listen - Engage in activities that promote understanding of statewide and local needs of BIPOC and religious groups to determine WIC-specific service improvements for these communities. Strategy: Relationship Building - Build relationships with cultural experts from each Native American community and other special populations to identify resources necessary for culturally sensitive service delivery. Strategy: Collaboratively Designed Services - Engage community leaders, organizations, and coalitions to curate culturally relevant service delivery improvements. Objective 2: Make Available Funding, Staffing, Training and Resources to Support Culturally Responsive Service Delivery - By 2026, 75% of BIPOC and religious groups served by WIC indicate in participant surveys that the services provided to them by WIC are culturally responsive. Strategy: Conduct regular Diversity, Equity, Inclusion (DEI) training for WIC employees and establish a WIC DEI committee. Strategy: Strategize funding to support cultural safety activities, training, and implementation.

Priority Area 5: Data Use and Quality Goal: Improve data quality and accuracy to enable data driven decision making for targeted service delivery. Rationale: The Montana WIC Program collects and utilizes several sources of data to make informed decisions concerning areas of need and to also measure change within the Program. Currently, the Program depends on the integration of robust M-SPIRIT data with the data visualization benefits of Tableau to aid State and local staff in identifying and understanding participants’ needs, utilization patterns, and other programmatic markers (WIC Needs Assessment 2021). Similarly, the WIC Program also has access to several large datasets including, but not limited to, MT PRAMS, MT hospital discharge data, MT Medicaid, and other statewide benefit programs. Data from these datasets are typically compared to and stratified by WIC participants but require the expert knowledge and skills of the DPHHS epidemiology department staff to analyze and interpret such data (WIC Needs Assessment 2021). Because the WIC program continually uses this high-quality data, it is imperative that data from the aforementioned sources are available when needed and use the same/similar indicators or metrics so as to enable comparison with State and National data sources. Furthermore, Program staff should be adequately trained to increase the usability of the data collected through M-SPIRIT and other systems. Only then will the WIC program be able to ensure that the data the Program is collecting and receiving is used most effectively. Objectives: Objective 1: Comprehensive WIC Data Quality Review & Plan - Complete a comprehensive WIC data quality review and data improvement plan by 2026. Strategy: Identify epidemiological resources to provide data quality and resource support. Strategy: Create dashboards for State and LAs to use to drive QI and Breastfeeding & Nutrition Plan priorities. Strategy: Data Utilization - Develop and disseminate regular data reports, including data visualizations, to clinics to enable data utilization. Objective 2: State-Wide Data Training for Improved Data Quality - By 2026, 100% of WIC staff are trained in data quality improvements as identified by the comprehensive WIC data quality review. Strategy: Data Training - Develop quality improvement and database training curriculums to empower local staff to become local clinic QI champions.

Priority Area 6: Funding Goal: Ensure that every Local Agency is within 5% of the funding formula compared to their requested budget by 2026. Rationale: Meeting the funding needs of local agencies is crucial to the success of the Program. However, 21% of Montana local agencies believed they received insufficient funding to meet their staffing, clinic hours, and service provision needs when surveyed in 2021. Similarly, other local agencies expressed that the amount of funding they received could not meet their supply, travel, or training needs in 2021 (MT WIC Needs Assessment Survey 2021). However, the problem is cyclical and complex: funding from the federal government is directly related to participation count, and since participation has been decreasing, so has the funding for all Local Agencies. With declining funds, the Agencies are limited in the services they can provide, which may then contribute to declining participation (WIC Needs Assessment 2021). As a result of this dilemma, local agencies must consider alternative funding sources to sustain the services of WIC Program staff and participants. Though this is the last priority listed, all previous priorities are dependent on adequate funding. Objectives: Objective 1: Equity of Funding Allocations Among WIC Local Agencies - Ensure all Local staff have an applicable understanding of funding allocations. Strategy: Training - Provide training to each clinic for interested and applicable staff on funding allocations. Strategy: Budget Solicitation - During the budget planning process, Local Agency Directors should both solicit input from staff and consider additional tasks undertaken to support their Nutrition and Breastfeeding Services Plan, in developing their draft annual budget. Objective 2: Identify Alternative Funding Sources - Pilot a mechanism of reimbursable services for Registered Dietitian Nutritionists and IBCLCs by 2026. Strategy: Billing - Identify pathways for private and public insurance reimbursement for RDN and IBCLC services. Strategy: Grants - Identify grant funding opportunities to support staff and other strategies. Strategy: Novel Pilot Projects - Investigate options for sustainably and effectively partnering with RDNs in clinical offices.

Local Agencies Alignment with State Nutrition and Breastfeeding Services Plan A crucial part of this planning process was the inclusion of Local Agencies to ensure relevancy at a local level and to align efforts across the State’s NBSP and the Local Agency NBSPs. Once the State NBSP was established, the objectives and strategies of the State NBSP were directly translated for use at a local level. Objectives and strategies that were relevant only at the State level were left out of the Local Agency NBSP version. From the translated version each Local Agency can choose their focus areas and have actionable steps to move initiatives forward in direct alignment with State efforts. This will align objective-based improvements across the State and allow for shared metrics to observe statewide effectiveness. Local Agency Nutrition and Breastfeeding Services Plan Priority Area 1: Increasing Participation Goal: Increase the percent of the eligible infants and children participating in Montana WIC by ten percent from 55.5% (2018) to 65.5% by 2026. Objective 1: Recruitment - Our agency either falls in the top 10 counties of “need” based on the Affirmative Action Plan and/or has the lowest reach of potentially eligible participants, so our Agency will increase the enrollment of potentially eligible participants in our county by 5% by 2026. . Strategy: Partnerships - Identify possible partners for recruitment efforts and establish appropriate MOUs with each partner. Strategy: Referral Processes - Promote referral processes that include warm handoffs and WIC-related anthropometric and/or hematologic measures as applicable with clinical partners. Strategy: Tribal - Meet with representatives from Tribal Nations in our area to address recruitment and referral needs among Tribal communities. Strategy: Marketing - Promote WIC services through outreach activities. Strategy: Novel Pilot Projects - Participate in a pilot project to investigate the options for digitizing the WIC process, i.e., online application/screening tool, appointment scheduling, and/or participant portal and telehealth options. Objective 2: Retention & Utilization - Increase the percent of certification months utilized.

Strategy: Best Practices for Retention – Implement best practices for participant retention. Note: Focus on children 1-5. Strategy: Best Practices for Utilization Outreach – Implement best practices for supporting participants that are under-utilizing benefits Strategy: Participant-centered Services - Resolve barriers to program participation with a focus on streamlining services to use participants’ time more effectively. Strategy: Remote Appointments - Maintain the option for remote appointments, when feasible, for clinics and families. Objective 3: Redemption - Improve food redemption rates. Strategy: Promoting WIC Foods – Make educational materials available to support participants in fully utilizing benefits. Strategy: Improve Store Experience - Address common issues, as identified by the State, across stores that are contributing to a negative store experience. Strategy: Redemption Outreach - Increase the number of participating grocery stores and/or use of alternative delivery methods (ex. mobile WIC stores), with an emphasis on rural areas and food deserts. Priority Area 2: Service Improvement & Expansion Goal: Increase access to the highest quality breastfeeding and nutrition services possible. Objective 1: Increasing breastfeeding duration - Increase breastfeeding duration for 6 & 12 months of age by 2026. Strategy: Stigma Reduction - Support community activities to reduce stigma around breastfeeding. Strategy: Promoting Breastfeeding in the Workplace - Collaborate with the MT Breastfeeding Coalition and other statewide health organizations to promote and educate employers on “Break Time for Nursing Mothers” law. Objective 2: Coordinate and Collaborate with Partner Groups - Maintain local partnerships with coalitions, collaboratives, and professional organizations to ensure WIC services are aligned with statewide initiatives and best practices. Strategy: Clinical Partnerships - Support and/or participate in projects in collaboration with healthcare providers Strategy: Perinatal Mental Health Collaborative - Support and/or participate in Perinatal Mental Health Collaborative work

Objective 3: Integration of WIC into Community Settings - By Fiscal Year 2026, participate in integration projects with healthcare providers and/or other interested community partners. Strategy: Nutrition Access Project & NAVA Tools – Participate with the State to establish best practices for integrating WIC and/or creating screening, education, and referral to WIC within healthcare settings as identified through the Nutrition Access Project. Strategy: Learn – Participate with the State to compile ideas on WIC integration models used in other states in both healthcare and community settings. Objective 4: Promoting breastfeeding peer counselor programs - Increase the percent of women participating in WIC that have access to Breastfeeding Peer Counselor Programs from 75.6% to 85% by 2026. At least 2 Peer Counselors will be Tribally affiliated and provide services to their tribal nations (none at baseline 2022). Strategy: Establish Breastfeeding Peer Support - Establish/expand our Breastfeeding Peer Counselor Program. Strategy: Tribal - Engage with the WIC Tribal liaison to initiate discussions around Breastfeeding Peer Counselor Programs. Strategy: Remote Appointments - Ensure adequate technology and equipment to enable remote Breastfeeding Peer Counselor Programs across clinics and/or agencies. Priority Area 3: Staffing Goal: Ensure all (100%) clinics are sufficiently staffed, according to Local Agency Directors and State Office recommendations, across various positions. Objective 1: Increase CLCs & IBCLCs - 100% of WIC agencies and 75% of WIC clinics have a CLC or IBCLC by 2026. Strategy: IBCLC Mentorship – Develop partnerships with local hospitals and organizations with existing IBCLCs for mentoring current CLCs to become IBCLCs. Strategy: CLC Training - Prioritize funding for CLC training, in-person or virtually at a local level. Objective 2: Support appropriate staffing levels for CPAs & RDNs -By Fiscal Year 2026, work with State to establish staffing levels for CPAs and RDNs based on clinic size, rurality, Affirmative Action Indicators, and other elements. Strategy: Establish Staffing Formulas - Aid the State office in establishing an appropriate staffing ratio for Local Agencies.

Strategy: Alternative Staffing Models- Aid state investigation into alternative staffing models such as paraprofessional pathways to becoming a CPA, or state employment of RDNs. Priority Area 4: Cultural Adaptations for Communities of Color and Religious Groups Goal: Improvements are made towards addressing health disparities by improving equitable access and culturally appropriate service delivery for communities of black, indigenous, people of color (BIPOC), and religious groups across the state of Montana. Objective 1: Learn and Listen - Engage in activities that promote understanding of local needs for BIPOC and religious groups to determine WIC-specific service improvements for these communities. Strategy: Relationship Building - Build relationships with cultural experts from each Native American community and other special populations to identify resources necessary for culturally sensitive service delivery. Strategy: Collaboratively Designed Services - Engage community leaders, organizations, and coalitions to curate culturally relevant service delivery improvements. Objective 2: Funding Utilization - Utilize funding, staffing, training, and resources to support culturally responsive service delivery - By 2026, 75% of BIPOC and religious groups served by WIC indicate in participant surveys that the services provided to them by WIC are culturally responsive. Strategy: Participate in regular Diversity, Equity, Inclusion (DEI) training for WIC employees. Priority Area 5: Data Use and Quality Goal: Improve data quality and accuracy to enable data driven decision making for targeted service delivery. Objective 1: Comprehensive WIC data quality review & plan - Participate in comprehensive WIC data quality review and data improvement plan by 2026. Strategy: Pilot dashboard to drive quality improvement and Breastfeeding & Nutrition Plan priorities. Objective 2: State-wide data training for improved data quality - By 2026, 100% of WIC staff are trained in data quality improvements as identified by the comprehensive WIC data quality review. Strategy: Data Training - Utilize online quality improvement and database training curriculums for staff to become local clinic QI champions. Priority Area 6: Funding Goal: Ensure that every Local Agency is within 5% of the funding formula compared to their requested budget by 2026.

Objective 1: Equity of funding allocations among WIC local agencies - Ensure all Local staff have an applicable understanding of funding allocations. Strategy: Training - Participate in training provided to each clinic for interested and applicable staff on funding allocations. Strategy: Budget Solicitation - During the budget planning process, Local Agency Directors should both solicit input from staff and consider additional tasks undertaken to support their Nutrition and Breastfeeding Services Plan, in developing their draft annual budget. Objective 2: Identify Alternative Funding Sources - Participate in a pilot program for reimbursable services for RDNs and IBCLCs by 2026. Strategy: Grants - Utilize grant funding identified by the state for opportunities to support staff and other strategies. Strategy: Novel Pilot Projects - Participate in pilot projects to inform creation of a best practices model for sustainably and effectively partnering with RDNs in clinical offices.

Monitoring and Dissemination The State Nutrition and Breastfeeding Service Plan will be publicly published on the Montana WIC website as Section I of the annually updated State Plan document. The Local Agency Nutrition and Breastfeeding Service Plan template (action plan) will be sent to Local Agencies to complete and send back to the State. These will be for internal use only and will inform the progress of these goals at the local level. The State WIC Office will review their State NBSP progress bi-annually and will monitor Local Agency NBSP progress on an annual basis. The overall plan will be reviewed and updated at least every three to five years.

References Citation Code Citation Data Years MT WIC M-SPIRIT Benefit Package Data 2021 Montana Department of Public Health and Human Services. 2021. WIC M-SPIRIT, "Percentage of Benefits Redeemed" 2021. Unpublished raw data. 2021 MT WIC Needs Assessment Survey 2021 Montana Department of Public Health and Human Services. 2021. MT WIC Needs Assessment Survey. Unpublished data. 2021 WIC MT Elg Census 2013–2018 U.S. Census Bureau. 2020. Profile of WIC Eligibility and Participation in Montana, 2018: Evidence from Administrative Records and the American Community Survey. Retrieved from: https://drive.google.com/file/d/1y67LmYil_3rn9dRRLD97XVGj0 XNI2NxU/view?usp=sharing. 2013–2018 WIC Needs Assessment 2021 Montana Department of Public Health and Human Services. 2021. MT WIC NeedsAssessment. Retrieved from: https://dphhs.mt.gov/assets/ecfsd/WIC/WICNeedsAssessment. pdf. 2021 WIC Part Count 2016–2020 Montana Department of Public Health and Human Services. 2020. WIC Participant Counts Data, 2020. Unpublished raw data. 2016–2020 WIC Staff Density 2021 Montana Department of Public Health and Human Services. 2021. WIC Staffing Density,2021. Unpublished raw data. 2021

Appendix State Nutrition and Breastfeeding Plan Priority Area Goal Objectives Strategy 1. Increasing Participation 1.1. Increase the percent of the eligible infants and children participating in Montana WIC by ten percent from 55.5% (2018) to 65.5% by 2026. 1.1. Recruitment - Agencies who either fall in the top 10 counties of “need” based on the Affirmative Action Plan and/or have the lowest enrollment of potentially eligible participants, will increase the potentially eligible enrollment in each county by 5% by 2026. 1.1.1 Partnerships - Identify possible partners for recruitment efforts and establish appropriate level (State or Local) Memorandums of Understanding (MOUs) with each partner. 1.1.2. Referral Processes - Promote referral processes that include warm handoffs and WIC-related anthropometric and hematologic measures as applicable with clinical partners. 1.1.3 Tribal - Meet with representatives from each Tribal Nation in Montana to address recruitment and referral needs among Tribal communities. 1.1.4 Marketing - Promote WIC services through statewide campaigns and support of Local Agency outreach activities. 1.1.5 Novel Pilot Projects - Pilot at least one project to investigate the options for digitizing the WIC process, i.e., online application/screening tool, appointment scheduling, and/or participant portal and telehealth options. 1.2. Retention & Utilization - Increase the percent of certification months utilized from 83% in 2018 to 99% in 2026. 1.2.1 Understanding Retention - Complete qualitative research with participants regarding utilization, use technology to gather feedback on participation in the first year, and shopping experiences (auto text, etc.), and / or discussing store experience at appointments.

1.2.2 Best Practices for Retention – Implement best practices for participant retention. Note: Focus on children 1-5. 1.2.3 Best Practices for Utilization Outreach – Implement best practices for supporting participants that are under-utilizing benefits. 1.2.4 Participant-centered Services - Resolve barriers to program participation with a focus on streamlining services to use participants’ time more effectively. 1.2.5 Remote Appointments - Maintain the option, when feasible, of remote appointments for clinics and families. 1.3. Redemption - Improve food redemption rates from 49% in 2020 to 60% by 2026. 1.3.1 Promoting WIC Foods – Identify and make available educational materials to be used by Local Agencies to support participants in fully utilizing benefits. 1.3.2 Improve Store Experience - Identify and address common issues across stores that are contributing to a negative store experience. 1.3.3 Redemption Outreach - Increase the number of participating grocery stores and/or research options for alternative delivery methods (ex. mobile WIC stores or appointment vans), with an emphasis on rural areas and food deserts. 2. Service Improvement & Expansion 2. Increase access to the highest quality breastfeeding and nutrition services possible. 2.1. Increasing breastfeeding duration - Increase breastfeeding duration for 6 & 12 months of age by 2026. For 6 months, increase breastfeeding duration rates from 27% to 60%. For 2.1.1 Stigma Reduction - Support community activities to reduce stigma around breastfeeding. 2.1.2 Promoting Breastfeeding in the Workplace - Collaborate with the MT Breastfeeding Coalition and other statewide health organizations to promote and educate employers on “Break Time for Nursing Mothers” law.

12 months, increase from 14% to 18%. 2.2. Coordinate and Collaborate with Partner Groups - Maintain partnerships with statewide coalitions, collaboratives, and professional organizations to ensure WIC services are aligned with statewide initiatives and best practices. 2.2.1 Food Security Coalitions - WIC’s participation with MT Partnership to End Childhood Hunger (MT-PECH) and MT Food Security Council (FSC) are vital efforts that align programs and create innovative interventions to decrease hunger. WIC will continue to actively participate, align, and work toward shared goals with MT-PECH and the FSC. 2.2.2 Clinical Partnerships - Support the nationwide effort to strengthen the linkage between medical clinics (pediatric and perinatal) and WIC by fostering and maintaining a strong working relationship with the MT AAP and MT ACOG chapters, and other healthcare associations, including expansion of the pilot Nutrition Access Project (NAP) with MT AAP. 2.2.3 MT Perinatal Mental Health Collaborative - Ensure that WIC aligns with state partners working on perinatal mental health and implements best practices around screening and referral for perinatal mental health within the WIC setting. 2.2.4 Social Determinants of Health - Continue to share information about WIC services and learn from other organizations about maternal and child health in all capacities to ensure that WIC continually updates and integrates best practices. 2.3. Integration of WIC into Community Settings - By Fiscal Year 2026, the MT WIC program will have 4 WIC agencies participating in integration projects with healthcare providers and/or 2.3.1 Nutrition Access Project & Innovative Technology Tools – Establish best practices for integrating WIC and/or creating screening, education, and referral to WIC within healthcare settings as identified through the Nutrition Access Project. 2.3.2 Learn – Compile ideas of WIC integration models used in other states in both healthcare and community settings.

other interested community partners. 3. Staffing 3. Ensure all (100%) clinics are sufficiently staffed, according to Local Agency Directors and State Office recommendations, across various positions. 3.1. Increase CLCs & IBCLCs - 100% of WIC agencies and 75% of WIC clinics have a CLC or IBCLC by 2026. (Baseline: Feb 2022 is 67% of agencies and 58% of clinics have either a CLC or IBCLC.) 3.1.1 IBCLC Mentorship – Support local agencies to develop partnerships with local hospitals and organizations with existing IBCLCs for mentoring current CLCs to become IBCLCs. 3.1.2 CLC Training - Prioritize funding for CLC training, in- person or virtually. 3.2 Identify and support appropriate staffing levels for CPAs & RDNs - By Fiscal Year 2026 the MT WIC will establish recommended staffing levels for CPAs and RDNs based on clinic size, rurality, Affirmative Action Indicators, and other elements as deemed appropriate. 3.2.1 Establish Staffing Formulas - Establish an appropriate staffing ratio and share staffing level data and tools to address gaps, with each Local Agency, annually. 3.2.2 Alternative Staffing Models- Investigate alternative staffing models such as paraprofessional pathways to becoming a CPA, or state employment of RDNs. 4. Cultural Adaptations for Communities of Color & Religious Groups 4. Improvements are made towards equity and culturally appropriate service delivery for communities of black, indigenous, people of color (BIPOC), and religious groups across the state of Montana. 4.1 Learn and listen - Engage in activities that promote understanding of statewide and local needs of BIPOC and religious groups to determine WIC- specific service improvements for these communities. 4.1.1 Relationship Building - Build relationships with cultural experts from each Native American community and other special populations to identify resources necessary for culturally sensitive service delivery. 4.1.2 Collaboratively Designed Services - Engage community leaders, organizations, and coalitions to curate culturally relevant service delivery improvements.

4.2 Make available funding, staffing, training, and resources to support culturally responsive service delivery - By 2026, 75% of BIPOC and religious groups served by WIC indicate in participant surveys that the services provided to them by WIC are culturally responsive. 4.2.1 Partner with MAWA to conduct regular Diversity, Equity, Inclusion (DEI) training for WIC employees and establish a WIC DEI committee. 4.2.2 Strategize funding to support cultural safety activities, training, and implementation. 5. Data Use and Quality 5. Improve data quality and accuracy to enable data driven decision making for targeted service delivery. 5.1 Comprehensive WIC data quality review & plan - Complete a comprehensive WIC data quality review and data improvement plan by 2026 5.1.1 Identify epidemiological resources to provide data quality and resource support. 5.1.2 Create dashboards for State and LAs to use to drive QI and Breastfeeding & Nutrition Plan priorities. 5.1.3 Data Utilization - Develop and disseminate regular data reports, including data visualizations, to clinics to enable data utilization. 5.2 State-wide data training for improved data quality - By 2026, 100% of WIC staff are trained in data quality improvements as identified by the comprehensive WIC data quality review. 5.2.1 Data Training - Develop quality improvement and database training curriculums to empower local staff to become local clinic QI champions. 6. Funding 6. Ensure that every Local Agency is within 5% of the funding formula compared to their requested budget by 2026. 6.1 Equity of funding allocations among WIC local agencies - Ensure all Local staff have an applicable understanding of funding allocations. 6.1.1 Training - Provide training to each clinic for interested and applicable staff on funding allocations. 6.1.2 Budget Solicitation - During the budget planning process, Local Agency Directors should both solicit input from staff and consider additional tasks undertaken to support their Nutrition

and Breastfeeding Services Plan, in developing their draft annual budget. 6.2 Identify Alternative Funding Sources - Pilot a mechanism of reimbursable services for Registered Dietitian Nutritionists and IBCLCs by 2026. 6.2.1 Billing - Identify pathways for private and public insurance reimbursement for RDN and IBCLC services. 6.2.2 Grants - Identify grant funding opportunities to support staff and other strategies. 6.2.3 Novel Pilot Projects - Investigate options for sustainably and effectively partnering with RDNs in clinical offices.

Section II: Local Agency Procedure Manual VII. Local Caseload Management A. Appointments Purpose Guidance for local agencies in making appointments for WIC applicants. Policy An appointment system will be used in local agencies for the delivery of WIC benefits. 1. General Information • Local clinics can establish a scheduling system to meet the needs of their participants. • Office hours will be posted so participants are aware of normal clinic hours and any non­ traditional hours. • Non-traditional hours are encouraged for WIC services to accommodate working, rural and student participants. • Drop-in hours are encouraged for all types of appointments. 2. Appointments • The request for service may be made in person, through WIC approved platform, or over the phone. • When new participants make an appointment with the WIC clinic, WIC staff must start a new participant record as this is considered their “initial” contact, or request for services. • Clinics will inform applicants of documentation requirements as well as expected time allotted for appointments. • All pregnant women will be contacted if their certification appointment is missed. o It is highly encouraged to contact any/all participants who miss any appointment for rescheduling. • Agencies are required to use the MIS for all appointment scheduling. o All participants with a cell phone number in the MIS will be opted into text reminders (may opt out at any time) via the appointment reminder system. A voice message will be sent to landlines. • Clinics will review reports of participants who are eligible for benefits and do not have an appointment, or missed their appointment and do not have current benefits, at least monthly. Contacts with these participants shall be prioritized to ensure issuance and services will be complete prior to “drop off” (2 months of non-participation).

Section II: Local Agency Procedure Manual VII. Local Caseload Management B. Outreach Purpose The purpose of outreach is to increase the visibility of the WIC Program to ensure potentially eligible persons in the state are aware of the WIC program and know where and how to seek services. Policy All Local Agencies will develop and implement an outreach system designed for their communities which will most effectively reach their potentially eligible population. 1. The local program is responsible for the following outreach efforts: • Send a public announcement to local media at least annually. The public announcement must include information about program benefits, including the eligibility criteria for participation and the location of the local agencies operating the program. Emphasis will be on reaching and enrolling eligible women in the early months of pregnancy, migrants, homeless individuals. This release must include the non-discrimination statement. o Local agencies are required to submit a copy of their announcement to the State Outreach Coordinator. o Examples of acceptable announcement formats are press releases, newspaper ads/articles, magazine ads/articles, radio announcements, and social media ads/posts. • Distribute state-approved outreach materials to offices and organizations that serve the WIC target population, including health and medical organizations, hospitals and clinics, public assistance offices, unemployment offices, social service agencies, farm worker organizations, Indian tribal organizations, childcare centers including Head Start and Early Head Start, agencies serving homeless individuals, and religious and community organizations in low-income areas. o Any outreach materials that include information about WIC program eligibility or participant requirements must be submitted to the State Outreach Coordinator for approval.  It is not required to submit every outreach effort that doesn’t include the above information. o Outreach materials of nominal value that are distributed to participants at conferences or other outreach events must be approved before purchasing if the state agency wishes to utilize WIC funds.

• It is recommended to keep a file with outreach material used at events, along with the annual public announcement, and a log of all activities. Be prepared to present these items during monitoring visits. o An additional interview with the State Outreach Coordinator will be part of the monitoring process. Please be prepared to talk about the outreach efforts your agency has done. • Include action plans related to recruitment and retention as part of annual local agency” plans” submitted to the State Office.

Section II: Local Agency Procedure Manual VII. Local Caseload Management C. Waiting Lists Purpose To ensure local agencies serve the highest priority WIC participants when the maximum participation level has been reached. Policy The following priorities will be applied by the Competent Professional Authority when vacancies occur after a local WIC program has reached its maximum participation level, in order to assure that those persons at greatest nutrition risk receive program benefits. 1. Waiting List Procedures • The State WIC Office will determine when waiting lists need to be implemented. o Applicants completely screened for eligibility and with a certification period established before being placed on the State Management Information System (MIS) waiting list will be used in the calculation of staffing/funding. o Applicants placed on a less formal waiting list after a brief screening to determine priority placement will not be used in the calculation of staffing/funding. 2. Waiting Lists • The primary purpose of waiting lists is to maintain a pool of interested applicants from which highest priority people can be selected to participate when caseload slots become available. An important element of the system is to give benefits to those of greatest need. • Applicants are ranked on the waiting list according to their Priority. o Applicants are removed from the waiting list in priority order. That is, Priority I’s are all served before Priorities II, III, IV, V and VI.  Each certification is a separate entity. A previous certification does not guarantee continued participation if a higher priority applicant is on the waiting list. • Applicants with valid VOC documentation will be placed at the top of waiting lists. • If a waiting list is started, local programs will keep lists of interested persons who visit the WIC program when no funds are available to provide benefits, or the maximum assigned caseload is reached. o The waiting list will include the applicant’s name, date placed on the waiting list, address or telephone number, and category. Individuals will be notified of their placement on a waiting list within 20 days of their initial contact with the clinic. • Waiting lists will be retained to be reviewed during monitoring visits.

3. Selective Screening • Selective screening of applicants may be done if only a few of the Priority Groups are being listed. o If the waiting list is comprised of low priority individuals, then alternative criteria may be selected to further subdivide the group to determine greatest need within the Priority. 4. Terminations Due to Lack of Funding • Under State direction, local programs will be required to reduce caseloads by terminating participants currently certified. • The State WIC Office will direct local programs as to which Priorities will be terminated. o The procedure will begin with the lowest Priority participants and continue up the Priority ranks until the State caseload reaches a level which can be served. o A participant terminated mid-certification will be given an End of Certification/Notice of Ineligibility Form and a minimum of 15-day notice that program benefits will be discontinued. The 15-day notice will include the prescribed food package to cover the time period. o If it is necessary to terminate participants above a Priority IV, affirmative action ranking will be assessed within each subsequent Priority group. • No new certifications will be performed while participants are being removed from the program. o Participants terminated or refused certification by the local agency will be placed on a waiting list.

Section II: Local Agency Procedure Manual VIII. Local Certification, Eligibility and Coordination A. Eligibility Guidelines Purpose To ensure Local Agencies apply current eligibility requirements to all WIC applicants. Policy The applicant must meet eligibility criteria for category, identity, residency, income and be at nutritional risk. 1. Categorical Eligibility • Women who are pregnant, breastfeeding (up to one year) or postpartum non- breastfeeding (up to 6 months), including women whose pregnancies ended early. • Non-biological mothers of WIC-eligible infants who meet the federal WIC definition of breastfeeding may be certified. Local agency staff shall consult the state office in these instances. Infants (birth to 1 year). • Children (1 year to up to 5 years). 2. Timeframe of Eligibility Determination • Timeframe for determination of eligibility status starts when the applicant submits the request for services via approved WIC platform, by phone, or in person. • Pregnant women and migrant farm workers will be notified of their eligibility status within 10 calendar days of the date of the first request for program benefits. o Local WIC clinics may receive an extension of the notification period to a maximum of 15 calendar days upon written request to the State WIC Office. o Request will include a justification. o Each local agency will attempt to contact each pregnant woman who misses her first certification appointment to reschedule the appointment. At the time of initial contact, the local agency shall request an address and telephone number where the pregnant woman can be reached. • All other applicants will be notified within 20 calendar days. • The initial contact date and first appointment offered must be documented for all initial certifications and if there is more than 2 months between the current certification request and the end of benefits from the last certification. 3. Identification • Proof of identity will be documented and scanned for each applicant at initial certification. o Proof of identity will be reviewed at all visits.  Visual personal recognition by WIC staff at benefit issuance or sub-certifications may be allowed once initial proof of identity has been documented and scanned.

• Identity for authorized representatives will be documented and scanned at certification, or at the first visit where they are present to represent the participant. • Proof of identity only needs to be rescanned if a participant or authorized representative’s name has changed. o Documents approved for identification, which must include the participant’s current name at the time of certification, include:  Driver’s License/State ID  Legal Custody Placement Notification for an Infant/Child  Birth Certificate  Certificate of Live Birth  Passport  Green Card  Social Security Card  Public assistance card or eligibility letter (Medicaid, HMK Plus, SNAP or TANF)  Tribal ID Card or Tribal Enrollment Letter  Crib Card  Hospital Identification (bracelet)  Immunization Card  Medical Record  School or work ID Card  Pay Stubs  Voter Registration Card  Health Benefits (Insurance Card)  Marriage Certificate/License  Other government Issued Documents • The State Office strongly encourages local agency staff to make sure the proof of ID is valid/not expired without creating a barrier to services. • Proof of identity should be submitted via state approved secure platform(s) or physical hard copy. o Participants may choose to submit documents via non-secure methods (email, text) o Staff should ensure that participants understand the difference between secure and non-secure submission methods. • If the applicant fails to bring in this documentation, but meets all other eligibility criteria (income, residence and nutrition risk as determined by local staff), the participant may be provided up to one month (current month) of food benefits, and require the appropriate documentation be brought within 30 days. Only one “proof” may be missing to allow a pending certification. o This is considered a “pending” certification and will expire after 30 days if the documentation is not provided. Only current month benefits may be issued in this circumstance.

o If past 30 days, a new certification must be completed to issue additional benefits. • An applicant with no proof of identity, such as a victim of theft, loss, or disaster, a homeless individual, or a migrant worker will sign a copy of the Montana WIC Affidavit Form (Montana WIC Affidavit-Spanish). Scan the form into the participant’s folder and issue benefits. o At each subsequent appointment, attempt to obtain proof of identity from the participant and document follow-up as needed. 4. Residency • Geographic Area o Applicants for Montana WIC services will live in Montana and may receive services at any local agency that meets the needs of the participant.  In the event a participant resides in another State and works or receives their healthcare, or whose location is physically nearer to WIC services in Montana, the participant may choose to receive WIC services in Montana.  The participant will not obtain services in both states, the local agency will contact the other state to ensure no dual participation exists. o If local WIC clinics have been instructed to implement waiting lists, participants will receive WIC services in the Montana WIC region in which they reside. • Residency Documentation o Residency will be documented and scanned in the applicant’s/participant’s folder at certification. Proof of residency will show the physical address where the applicant currently lives/resides and will match the physical address listed in the applicant’s/participant’s folder as recorded on that day that it was verified (this may be found in “history” if the address is updated during the certification period).  Participants living on a reservation, and seeking services at a reservation clinic, may use their mailing address as a form of address proof, including PO Boxes.  Participants living on a reservation, and seeking services at a reservation clinic, may document their place of residency with a written statement with the location described to the best of their ability. o If residency changes during a certification, the MIS will be updated with accurate information.  It is not required to scan proof of address outside of certification visits.  If the new address proof is provided and scanned into the participant folder, update the proof drop down to match the MIS. o If the new address proof is not available, update data in the demographics screen only, and ask for proof to be brought to the next certification appointment if applicable. o Documentation of residency will be:  Any document (mailed* or printed) with a(n) applicant/participant’s current physical address (or mailing address for reservation participants), such as:  Recent pay stub

 Utility or phone bill  Public Assistance documentation (agency letter or electronic verification printed)  Driver’s License (if address is same as that reported)  Current vehicle registration with current address  Recent bank statement  Rental agreement  Mortgage statement  Statement by City/County Address Coordinator or another authorized designee  Hospital certificate of live birth  Tribal ID or Tribal Membership letter * Note that “mail” (envelope) does not need to have applicants name on them but must have the reported address.  If the above cannot be obtained, a note from a 3rd party verifier may be used for the current certification (new verification for each certification is required).  The note must contain a date, physical address that matches the MIS, and signature from 3rd party verifier.  A 3rd party verifier is defined as a reliable source who can verify where an applicant/participant lives and who is not a WIC staff member. • If the applicant fails to bring in this documentation, but meets all other eligibility criteria (income, ID, and nutrition risk as determined by local staff), the participant may be provided up to one month (current month) of food benefits, and require the appropriate documentation be brought within 30 days. Only one “proof” may be missing to allow a pending certification.  This is considered a “pending” certification and will expire after 30 days if the documentation is not provided. Only current month benefits may be issued in this circumstance. o An applicant with no proof of residency, such as a victim of theft, loss, or disaster, a homeless individual, a migrant worker, or a person holding a VOC card will sign a copy of the Montana WIC Affidavit Form (Montana WIC Affidavit-Spanish). Scan the form into the participant’s folder and complete the certification before issuing benefits. o Residency proof should be submitted via state approved secure platform(s) or physical hard copy Participants may choose to submit documents via non-secure methods (email, text) o Staff should ensure that participants understand the difference between secure and non-secure submission methods. • Special Residency Circumstances: o Migrant Worker:  A fixed address is not an eligibility criterion for participating in the Montana WIC Program.

 The migrant’s place of employment can be used as a physical address.  The local WIC clinic’s address can be used for physical address if no other information is available. o Homeless/Institutions:  A fixed address is not an eligibility criterion for participating in the Montana WIC Program.  The local WIC clinic’s address can be used for physical address if no other information is available.  A homeless individual is defined as someone lacking a fixed and regular nighttime residence, staying in a temporary shelter, temporarily living with others in their residence (not to exceed 365 days) or staying in a place not designated as a regular sleeping accommodation.  Homelessness or an institutional living condition is defined as:  A public or private place not designated for, or ordinarily used as, a regular sleeping accommodation for human beings.  Temporary accommodation in the residence.  A facility that provides temporary residence for individuals intended to be institutionalized.  A supervised publicly or privately-operated shelter (including a congregate shelter, or shelter for victims of domestic violence) designed to provide temporary living accommodations.  For residents in a homeless shelter or institution to qualify for WIC benefits the facility will comply with the following conditions:  The facility does not accrue financial or in-kind benefit from a person’s participation in the WIC Program (i.e., by reducing its expenditures for food service because its residents are receiving WIC foods).  Foods provided by the WIC Program are not incorporated into a communal food service but are available exclusively to the WIC participant for whom they were issued.  The facility places no constraints on the ability of the participant to partake in the supplemental food and nutrition education available under the WIC Program requirements.  Local agencies will request a signed statement that the facility meets the criteria in this policy and keep this statement on file for monitoring purposes. See Homeless Facility Statement.  This signed statement must be completed every two years.

5. Income Eligibility • Guidelines o WIC Income Eligibility Guidelines are updated annually. Use the following table to determine WIC income eligibility. Income Eligibility Guidelines (Effective from July 1, 2025 to June 30, 2026) Federal Register Vol. 85, No. 31433 Household size (Including unborn): * Annual Monthly 2 x Monthly Bi-Weekly Weekly 1 $28,953 $2,413 $1,207 $1,114 $557 2 $39,128 $3,261 $1,631 $1,505 $753 3 $49,303 $4,109 $2,055 $1,897 $949 4 $59,478 $4,957 $2,479 $2,288 $1,144 5 $69,653 $5,805 $2,903 $2,679 $1,340 6 $79,828 $6,653 $3,327 $3,071 $1,536 7 $90,003 $7,501 $3,751 $3,462 $1,731 8 $100,178 $8,349 $4,175 $3,853 $1,927 Additional Family Members Add + $10,175 + $848 + $424 + $392 + $196 *If a pregnant woman does not meet the traditional income standard, her eligibility will be assessed using a household size increased by one, or the number of expected unborn(s) during the pregnancy in question. The unborn(s) will not be added to the household size when a household is income eligible without counting the unborn(s). • In situations where the household size has been increased for a pregnant woman, the same increased household size will also be used for any of her categorically eligible family members. • Local WIC clinic staff may not implement this policy in individual cases where increasing a pregnant woman’s household size conflicts with cultural, personal or religious beliefs of the applicant/participant. • When determining household size, students away at college may be counted. • Joint custody – household determination will be based on caregiver present at time of certification.

• Income Determination o A household is defined as all persons, related or unrelated, living together in the same dwelling and sharing financial resources and costs, except for foster children.  Two separate households may reside under the same roof. Staff should ask specific questions to determine if this is the situation.  An example of this situation may include a couple who divides household resources, pay bills independently, and file taxes separately. o Income is defined as the gross cash income before deductions for the household (i.e., income taxes, employee’s social security taxes, insurance premiums, bonds, etc.) and includes the following:  Monetary compensation for services, including wages, salary, commissions, or fees  Net benefits for farm and non-farm self-employment only  Dividends or interest on savings or bonds  Income from estates, trusts, or net rental income  Social Security benefits  Public assistance or welfare payments (cash benefits)  Unemployment compensation  Pensions, Veteran’s payments, or annuities  Alimony or child support payments  A regular contribution from person’s not living in the household (documented)  Net royalties and other cash income including, but not limited to, cash amounts received or withdrawn from any source, including savings, investments, trust accounts and other resources which are readily available to the household o Current income is all income received by the household during the month (28-31 consecutive days’ worth) prior to the date the application for benefits is made. Income will be documented at all certifications and when the participant indicates a change in income.  When the sole support of the family has been authorized to receive unemployment benefits, current refers to income that will be available to the family in the next 30 days.  If the average income over the past 12 months is a more accurate indicator of the household’s income status, that may be used as current income.  If income has recently changed and the previous 30-day period is not reflective of earnings anticipated going forward, the determination should be made based on information available at the time of certification.

 If unemployment or other income is anticipated in the following 30 days, this income may be documented if available. o Income documentation can be:  Adjunctively Eligible programs  An award letter or electronic verification (SIS or screenshot printout from eligibility system) will be acceptable as documented eligibility.  Payroll check stubs (last 28-31 days)  Only one pay stub is required for participants on a fixed pay schedule (ie- salary).  The most recent pay stub must not be dated more than 30 days prior to the documentation submission date or the first certification appointment.  A documentation submission date can be established when an applicant/participant submits documentation from the applicant’s initial request for benefits until the certification is considered complete.  Example of acceptable proofs timeline: • Dec 1- family has certification appointment and presents with ID and residency proof but no income. They are not adjunctively eligible. • Dec 15- participant uploads two, 2-week paystubs, the most recent one is dated Nov 10th  Most recent tax return (adjusted gross income)  Award letter from unemployment  Award letter from Social Security Income  Lump sum payments when put into a savings account and the household regularly draws from that account for living expenses, the amount withdrawn is counted as income o If income changes at any time during the certification period, the participant must notify the local agency for an eligibility evaluation. o Income proof can be used for other household member certifications for up to 30 days. Documentation must be transferred into the applicant’s chart that’s being certified.  Income proof should be submitted via state approved secure platform(s) or physical hard copy Participants may choose to submit documents via un- secure electronic means.  Staff should ensure that participants understand the difference between secure and non-secure submission methods.

o If the applicant fails to bring in this documentation but meets all other eligibility criteria (residence, ID, and nutrition risk as determined by local staff), the participant may be provided up to one month (current month) of food benefits, and require the appropriate documentation be brought within 30 days. The Montana WIC Affidavit form (Montana WIC Affidavit-Spanish) must be signed self-declaring income and scanned into the record. Only one “proof” may be missing to allow a pending certification.  This is considered a “pending” certification and will expire after 30 days if the documentation is not provided. Only current month benefits may be issued in this circumstance.  Verbal acceptance of the WIC Affidavit form (Montana WIC Affidavit-Spanish) by the participant is permittable during remote appointments. Documentation of verbal acceptance must be entered into the participant’s chart. • Self-Employment Income o Self-employed persons should use last year’s income as a basis to project their current year’s net income. Documentation will be the most recently completed Internal Revenue Service (IRS) tax return using the net income rather than adjusted gross income. o For a household with income from wages and self-employment, each amount will be listed separately. If there is a business loss, income from wages will not be reduced by the amount of the business loss. o If income from self-employment is negative, the income amount will be listed as zero. Complete the Negative Income Statement and scan it into the applicant’s/participant’s folder along with supporting documentation (i.e., taxes). • Cash Income o Use the Montana WIC Affidavit Form (Montana WIC Affidavit-Spanish) for anyone declaring cash income. • Zero Income o Use the Zero Income Statement for anyone declaring zero income. Local WIC staff are to scan the completed form into all applicable household members’ folders. At subsequent appointments you may follow up to see if income has changed and reassess as needed.  Verbal acceptance of the zero-income statement by the participant is permittable during remote appointments. Documentation of verbal acceptance must be entered into the participant’s chart. o Anyone with zero income will be referred to all appropriate assistance agencies in the area and that referral will be documented in the applicant’s/participant’s folder. • Presumptive Eligibility for Pregnant Women o Pregnant women who meet the income, ID and residency requirements may be determined eligible and receive benefits for a period up to 60 days to allow time to

schedule the full assessment, including assignment of risk codes. Risk code 503 shall be assigned by a CPA once documentation of income, ID and residency have been received, and benefits issued immediately. Hemoglobin may be deferred up to 90 days in this situation.  Presumptively eligible women who are missing either ID or residency may also be certified as “pending” for up to 30 days if income eligibility is determined. • Adjunctive Eligibility o Adjunctive eligibility is defined as automatic income eligibility for applicants/participants who report they are enrolled in a qualifying State or Federal program in Montana. o Local agencies must first attempt to determine if applicant is adjunctively eligible before performing traditional income screening.  Proof will be verified using SIS, eligibility letter or electronic verification (printed and scanned) prior to the certification appointment.  Programs providing adjunctive eligibility include:  Supplemental Nutrition Assistance Program (SNAP – formerly “Food Stamps”)  Temporary Assistance for Needy Families (TANF)  Healthy Montana Kids Plus (HMK-Plus) and Medicaid  Food Distribution Program on Indian Reservations (FDPIR)  School Lunch Program (free and reduced-price meals)  If a school qualifies for the Community Eligibility Provision (CEP) for the entire school to received free school lunch without verification of income, this may not be used for WIC adjunctive eligibility.  Best Beginnings Childcare Scholarship- Traditional Eligibility  Graduated Eligibility is not allowed o Search and Inquiry System (SIS)  Provides electronic verification for SNAP, TANF, Healthy Montana Kids Plus and Medicaid.  Tribal Programs TANF will not appear in SIS and must be verified with an eligibility letter.  Procedures for WIC clinics to access SIS may be obtained by contacting the State WIC helpdesk.  Applying one household member to determine adjunctive eligibility for the entire household, all family members’ state WIC IDs will be entered under this person in SIS. o Applicants/participants using adjunctive eligibility do not need to provide additional income proof.  They must self-declare their income to be recorded as part of the certification process.

o Household Adjunctive Situations  SNAP or TANF  If the applicant/participant, or member of the household, is currently eligible to receive SNAP or TANF, the entire household of categorically eligible participants will be determined income eligible. o Healthy Montana Kids Plus and/or Montana Medicaid  If a member of the household is a pregnant woman or an infant who currently has active Medicaid, all household members applying for WIC will be determined income eligible.  If the applicant/participant is a breastfeeding woman or postpartum woman and currently has active Medicaid , the associated infant will be determined income eligible.  If the applicant/participant is a child and they are currently has active Medicaid , only they will be determined income eligible. o Applicants/participants found adjunctively eligible do not lose their WIC eligibility upon cessation of benefits from TANF, SNAP, HMK Plus or Medicaid. A decision about the applicant’s/participant’s continuing WIC eligibility will be based upon a reassessment of the household size and income. PROGRAM QUALIFIES Medicaid- Child Only the child who has Medicaid Medicaid- Infant Entire Household Medicaid- Pregnancy Entire Household Medicaid- Postpartum Mom and Infant SNAP Entire Household TANF Entire Household School Lunch*

schools with community eligibility provision do not qualify Entire Household FDPIR Entire Household Best Beginnings Childcare Scholarship Traditional Eligibility Only Entire Household

• Income Not Counted o Income not to be reported or counted in the determination of a household’s eligibility includes:  Any cash income or value of benefits a household receives from any Federal program that excludes such income by legislative prohibition, such as the value of SNAP benefits.  Any subsidy a household receives through the prescription drug discount card program.  Student financial assistance, such as grants and scholarships, provided for the costs of attendance at an educational institution received from any program funded in whole or part under Title IV of the Higher Education Act of 1965.  Pell Grant  Supplemental Educational Opportunity Grant  State Student Incentive Grants  National Direct Student Loan  PLUS- Parent Loan for Undergraduate Students  College Work Study  Byrd Honor Scholarship  Loans, such as bank loans or private student loans, since these funds are only temporarily available and must be repaid.  Income received under the National Flood Insurance Program (NFIP).  Funds the Department of Defense is providing to certain members of the Armed Forces and their household through the Family Subsistence Supplemental Allowance (FSSA).  The value of in-kind compensation, such as military on-base housing, or any other non-cash benefit. Military cash housing is not counted as income, but other military benefits received in cash, such as food or clothing allowances are.  Occasional earnings received on an irregular basis (i.e., not reoccurring, such as payment for occasional babysitting or mowing lawns).  If overtime is regularly relied upon, it will be counted as income. If it is infrequent, it does not count.  Earned Income Tax Credit funds received by a member of the household, whether received throughout the year or as a lump sum.  Large cash settlements (i.e., funds provided as a compensation for a loss that must be replaced, payment from an insurance company for fire damage to a house).

• Changes to Income during a Certification o If a participant’s income changes at any time during the certification period, they must notify the local agency for eligibility evaluation. o The local agency must reassess a participant’s income eligibility during the current certification period if the local agency receives information indicating that the participant’s household income has changed. However, such assessments are not required in cases where sufficient time does not exist to effect the change. Sufficient time means 90 days or less before the expiration of the certification period. o The local agency must disqualify a participant and any other household members currently receiving WIC benefits who are determined ineligible based on information received.  Adjunctively eligible WIC participants may not be disqualified from the WIC program solely because they, or certain family members, no longer participate in one of the other specified programs. The local agency will ensure that such participants, and other household members currently receiving WIC benefits, are disqualified during a certification period only after their income eligibility has been reassessed based on the income screening procedures used for applicants who are not adjunctively eligible. • Special Income Circumstances: o Military:  Income to be included/excluded.  In temporary care  Local WIC staff may be confronted with household composition changes in which military family members are deployed overseas or are temporarily absent from the home. This may cause military dependents to be in the temporary care of friends or relatives. The most important rule to apply to all applicants, including minors, is that this household will have its own source of income. 1) Situation 1: Count the absent parent(s) and the child(ren) together as the household and use parent(s) income. 2) Situation 2: Count the child(ren) and/or remaining parent as its own household. This household would have its own source of income (i.e., the dependent’s allotment and/or at home parent’s income). If this income is not able to sustain the household and the household is living with other relatives or friends, please use Situation 3. 3) Situation 3: Consider the child(ren) to be part of the household in which the person(s) is residing (i.e., grandparents).

o Migrant Worker:  Income verification located on a VOC can be used to satisfy the income requirement, even if the VOC is expired, if the income verification was performed in the last 12 months.  In the instance of an expired VOC, the local agency staff must complete a certification. o Homeless/Institutions:  Income documentation is not required in homeless situations where obtaining documentation would present an unreasonable barrier to service. Homeless individuals can self-declare their income if accompanied by a signed statement of explanation. o Foster Child:  A foster child is a household of one and the income determination is based solely on the foster child’s income.  All foster children, who are in the legal custody of the State Department of Child and Family Services, are eligible for Medicaid. If there is a delay in the verification of this eligibility, foster payments to the family may be assessed for income only for the foster child.  Income includes funds provided by the Human Services Agency which are specifically identified by category for the personal use of the child.  Where the child is placed (kinship vs. licensed home) does not determine whether the child qualifies as a “foster” child, but rather the legal custody being with the State or tribal entity.  Other funds received by the child, such as money which may be provided by the child’s family, or social security money, will be counted as income.  Child-only TANF and SNAP may also apply in these situations and should be checked prior to using the Zero Income Statement.  If no income proof is available for the child at certification, fill out a Zero Income Statement.  A foster child is not included in the foster parents’ household nor is income received for the foster child’s care counted in the foster parents’ household income.  If a foster child is returned to his/her birth family, an income eligibility evaluation will be completed based on the new household income. o Waiver for Native Americans living on Reservations:  Households applying to participate in WIC at a reservation clinic that has been granted this waiver, who has an enrolled tribal member of the governing tribe(s) in the household, may show a tribal enrollment identification as income proof if applying for WIC on that reservation. Any household member’s enrollment will qualify the applying categorically eligible member(s) of the household.

o The following reservations have been approved for the waiver by USDA due to most residents making less than 185% poverty level according to census data:  Fort Peck  Fort Belknap  Rocky Boy  Crow  Northern Cheyenne  Blackfeet  Documentation of the household member’s enrollment will be scanned into the applicant’s/participant’s folder.  The local agency will inform each applicant household of the maximum family income allowed for that applicant’s family size.  The local agency shall ensure that the applicant, or the authorized representative, signs the Tribal Eligibility Statement attesting that the applicant’s family income does not exceed the maximum on the current income eligibility guidelines.  Verbal acceptance of the Tribal Eligibility Statement by the participant is permittable during remote certifications. Verbal acceptance must be documented in the participant’s chart.  Failure to present a tribal enrollment documentation will require the applicant/participant to present standard income documentation. o Temporary Loss of Income (furlough)  Applicants who report temporary loss of income due to furlough, will have income assessed based on current income at the time of application, with consideration of known income for the following 30 days (i.e., unemployment or other known financial support).  Local agency staff should assess if applicant is using income from other sources (i.e., savings, investments, any additional money received, etc.)  Income will be followed up on monthly.  Monthly contact does not have to be in-person.  Documentation of follow up must be in participant folder monthly. o Students: No special circumstances. o Adopted Child:  When a child has been placed in a permanent home, the child is considered a member of that household.  If child’s adoption is pending, the child is still considered a household of one. o Alimony/Child Support:

 Any money received by a household in the form of alimony or child support is considered as income to the receiving household.  Any money paid out for alimony or child support may not be deducted from that household’s reported gross income. o Emancipated Minor:  A minor living alone and without economic support from other persons, or living with relatives or friends, but as a separate household, is a household of one.  If the household is one household (all persons living together in the same dwelling and sharing financial resources and costs) all income and household members will be included to determine income eligibility. 6. Nutrition Eligibility Determination • After a complete nutrition assessment, all applicants will be assigned all applicable nutrition risk factors to be eligible to receive WIC benefits. Risk code assignment will determine priority level. See attachment Nutrition Risk Code Table for details.

Section II: Local Agency Procedure Manual VIII. Local Certification, Eligibility and Coordination B. Certification Procedures Purpose To provide guidance for local agencies to apply appropriate certification procedures based on applicant’s category. Policy Local agencies assess applicants for WIC eligibility and issue program benefits. 1. Certification Periods At the time of the certification if the participant’s category is: The Certification Period is: Pregnant Woman During pregnancy and to the end of the month the woman reaches six weeks following termination of pregnancy. Breastfeeding Woman Up to the end of the month of their infant’s first birthday. Non-Breastfeeding Postpartum Woman Regardless of how the pregnancy ended, up to the end of the sixth month postpartum. Infant younger than 6 months Up to the end of the month of their first birthday. Infant older than 6 months Up to the end of the six-month following certification (may be certified beyond the month of their first birthday.) Children In twelve-month intervals up to the end of the month of their fifth birthday. 2. Demographics • Physical Presence  Physical presence is required for all initial certifications. • Physical presence at initial certification may be waived in certain circumstances with State Office written approval.  Applicant/participant can choose to attend all subsequent appointments in-person or remotely via telephone or other electronic means.

 All appointment types must be available remotely.  All communications with participants must be conducted via state- approved methods.  In-person services must be made available to all participants.  Staff can request participants attend in-person appointments if high-risk status, nutrition care plan, or staff assessment determines need.  With anthropometric data and eligibility proof available, physical presence requirements may also be waived in the following situations:  Infants less than 8 weeks of age may not need to be present for their initial certification. Local agency staff must document an acceptable reason why the infant cannot be present. Participant preference is not an allowable reason for waiving physical presence requirements. All certification information must be available. Self-reported birth data is acceptable if medical records are not available.  Any participant who has a disability. Reason may include, but is not limited to, confinement to bed rest, a serious condition that requires equipment that is difficult to transport, or an illness that may be contagious or exacerbated by coming into the WIC clinic. Healthcare provider documentation is required for this exemption and shall be scanned into the chart. Other household members are not exempt from physical presence in this situation.  Regardless of physical presence, all other certification requirements will be met. • Voter Registration o Local WIC staff will ensure age-appropriate participants, or their caretakers/authorized representative, are asked if they are interested in registering to vote. Voter registration must be offered at all certifications, subsequent certifications, and address changes. Local WIC staff will document the response in the participant folder. o Every participant is required to see a disclaimer about his or her voting rights. The participant must indicate if they would like to register, do not want to register, or are already registered to vote. The participant will be asked to sign the disclaimer for understanding. If refused, this will be documented on the disclaimer and scanned. o If completing an appointment remotely, a signature is not required. Staff must document authorized representative verbal acknowledgment of voting rights in each participant chart. o It is the local agency’s responsibility to have voter registration forms available and assist in the submission of forms. o If completing an appointment remotely, staff must offer to send a voter registration form.

o The Voter Registration Disclaimer can be completed per household. • Authorized Representative(s) o A primary authorized representative will be identified at the certification appointments, and will be one of the following:  The participant, in the case of a pregnant or post-partum woman  The parent or legal guardian, in the case of an infant or child  A person identified by the parent or legal guardian at the certification appointment o If an alternative authorized representative is designated by the participant/primary authorized representative, it must be done in person or in writing (to be scanned into the participant folder).  A primary authorized representative may remove alternate representatives at any time during the certification period.  Up to two alternative authorized representatives may be identified and documented in the WIC system. Alternative authorized representatives may not change the status of the primary representative. If there is a legal custody change, and documents are present, then a household change will be completed to update the primary authorized representative.  Either a primary or alternative authorized representative may:  Attend appointments on behalf of the participant  Provide necessary information, and receive education on behalf of the participant  Sign necessary documents, such as the rights and responsibilities and voter disclaimer, and  Obtain information about the participant, which has been documented in the chart since the current certification started o The first time a primary or alternate authorized representative presents at the clinic, they will provide ID, which will then be scanned into the participant’s folder. o All authorized representatives will be held responsible to understand and abide by the rights and responsibilities of the program and will be held responsible for any actions that violate program rules and regulations. • Proxy o A proxy is someone that can go shopping on behalf of a participant, with the card and PIN provided by the primary cardholder/authorized representative. o The primary cardholder/authorized representative will be held responsible to educate their proxies on the use of the cards, authorized foods, and program rules.

o A proxy will not be designated in the WIC system/participant chart. o A proxy will not be authorized to complete appointments on behalf of the participant. o A proxy may not obtain confidential information obtained in the participant chart. 3. Height and Weight • Anthropometric data collection o Height or length and weight are required elements of certification and mid- certification appointments. Additional measures are best practice where indicated in specific categories below or when the CPA has a concern about growth trends. o Infants less than 8 weeks old may have birth length and weight reported verbally by parent/guardian at initial certification. o Written documentation from the provider will be signed and dated if hand-written or be a printout from the medical record (via portal or EHR) and scanned into the participant’s folder.  Data up to 60 days old may be used for certification or sub-certification. • Anthropometrics for remote certifications and mid-certifications o Participants not presenting in-person may have required anthropometric measurements deferred for up to 60 days. o The local agency must make concerted efforts (at least one attempt in advance of, or at the time of the appointment, or up to 60 days after) to obtain anthropometric data. These efforts must be documented in the participant’s chart.  Anthropometrics will be obtained through referral agencies via data sharing agreements, release of information, or other relevant technologies such as participant portals.  Anthropometrics collected from any of the above methods will be scanned into the participant’s folder.  Measurements will be entered into the participant’s chart and a CPA note of assessment will be added including review of any resulting risk codes.  Local agency staff must follow-up with the participant regarding assessment of measurements at the next scheduled nutrition education contact or sooner. • Women o At certification, the height and weight will be reflective of a woman’s current category. Breastfeeding women will be re-weighed at mid-certification. Pregnant women will be re-weighed at each appointment where they are physically present. o If a nutrition risk code indicating a current/potential weight concern is documented, the participant will be referred according to the attachment High Risk Referrals. • Infants

o Recumbent length and weight will be recorded at certification and mid-certification at a minimum. o Length and weight may be monitored about quarterly, ideally around 3, 6, and 9 months of age.  Obtaining referral data from the provider well-baby visits is encouraged to reduce the burden of re-measuring for staff and the family. o If a nutrition risk code indicating a current/potential growth concern is documented, the participant will be referred according to the High-Risk Referrals. • Children o Height and weight will be taken at certification and mid-certification. o If a nutrition risk code indicating a current/potential growth concern is documented, the participant will be referred according to the High-Risk Referrals. • Proper anthropometric techniques o Scale and Measuring Board Maintenance Requirements  Scales will be checked for accuracy at least once per year.  Scales may be checked by contracted professionals or internally with “standard” weights.  If the device is deemed inaccurate, the local agency will have it fixed, calibrated (if possible), or replaced.  Portable scales/length boards/stadiometers will be checked and/or calibrated after each time the scale is moved.  Length boards/stadiometers will be checked with standard length rods or a metal tape measure.  Calibration techniques and resolving issues will be according to manufacturing guidelines. • Equipment o Scales:  The scale will be durable, accurate, and safe.  Infant scales will have no sharp edges and a large enough tray to adequately support an infant or young child who weighs up to 40 pounds or a large enough platform to support the individual being weighed.  The child/adult scale will weigh to nearest 1/4 pound.  Infant scales will weigh to the nearest ounce.  The scale will be zeroed easily without weight o Length boards/Stadiometers  Length boards for infants will be sturdy, easily cleaned, and specific to their purpose.

 The recumbent length board will have a stationary headpiece and a smoothly moveable foot piece, perpendicular to the tape.  The stadiometer will have a vertical board with an attached metric rule and a horizontal headpiece that can be brought into contact with the most superior part of the head.  The length board/stadiometer will have a firm, flat horizontal surface with a measuring tape in 1/8-inch increments. o Technique for measuring weight  Infants and children up to 24 months will be weighed nude or with a clean diaper on; shoes will be removed.  Children older than 24 months will be weighed wearing light clothing without shoes.  Center the infant on the scale tray.  Weigh to the nearest ounce.  An alternative measurement technique can be used if needed.  Have the authorized representative stand on the scale, record the first weight, then have the parent hold the child and record the second weight. Subtract the first weight from the second weight to determine the child’s weight. Document this weight in the participant folder. o Technique for measuring length  Measure infants younger than 24 months of age, or children aged 24 to 36 months who cannot stand unassisted, in the recumbent position.  Shoes and hair accessories will be removed.  The infant/child should be placed on his back in the center of the length board so that the child is laying straight, and his shoulders and buttocks are flat against the measuring surface. The child's eyes should be looking straight up. Both legs should be fully extended, and the toes should be pointing upward with feet flat against the foot piece.  One measurer holds the infant’s head gently, cupping the infant’s ears, with the infant looking vertically upward and the crown of the head in contact with the headpiece. Make sure the infant's chin is not tucked in against his chest or stretched too far back.  The measurer aligns the infant’s trunk and legs, extends both legs, and brings the foot piece firmly against both heels. The measurer places one hand on the infant’s knees to maintain full extension of the legs. o Techniques for stature measurement  A woman or a child over 24 months, if she/he can stand unassisted, following directions for proper positioning.

 The woman or child should stand on the footplate of the stadiometer without shoes. The individual is positioned with heels close together and against the wall or backboard, legs straight, arms at sides, shoulders relaxed. Ask the person to inhale deeply and to stand fully erect without altering the position of the heels. Make sure that the heels do not rise off the foot plate.  Lower the perpendicular headpiece snugly to the crown of the head with enough pressure to compress the hair. To ensure an accurate reading, the measurer’s eyes should be parallel with the headpiece.  Measure to the nearest 1/8 inch. 4. Blood Screenings • The hemoglobin test is a laboratory test to determine the concentration of hemoglobin in the blood. The HemoCue® and Masimo Pronto systems are the most common devices used in the Montana WIC clinics. If investigating other methods of hematological screening, please contact the State Office. • Follow the manufacturer’s instructions for calibration, cleaning, and maintenance. • Follow the manufacturer’s instructions for accurate testing. • Sample should not be taken from the toe for infants who have started walking or children over the age of one. • Valid Blood Screening Data • Please see attachment Blood Screening Procedures for standard process. • Blood screenings received from a source other than WIC will be documented and scanned into the participant folder. • Data from another qualified source may be used within 90 days. • The hemoglobin screening test shall be done at certification, when appropriate, for participants that are physically present. • Blood screening data for remote certifications and mid-certifications  Participants not presenting in-person may have required blood screening data deferred for up to 90 days.  The local agency must make concerted efforts (at least one attempt in advance of, or at the time of the appointment, or up to 60 days after) to obtain referral data for blood screening data. These efforts must be documented in the participant’s chart.  Blood screening data will be obtained through referral agencies via data sharing agreements, release of information, or other relevant technologies such as participant portals.  Blood screening data collected from any of the above methods will be scanned into the participant’s folder.  Data will be entered into the participant’s chart and a CPA note of assessment will be added including review of any resulting risk codes.

 Local agency staff must follow-up with the participant regarding assessment of measurements at the next scheduled nutrition education contact. • Women o All pregnant women will have a screening performed at certification. o Data will reflect current categorical status. o Breastfeeding and postpartum women will have one screening after termination of pregnancy (best results tend to be between four to six weeks postpartum). o If screening is at or above the established cut-off value for anemia, no additional test is required. o If screening is below the established cut-off value for anemia, follow-up screening will be performed in three months.  See Attachment Hemoglobin Reference Chart.  If below the cut-off at second screening, refer according to the High-Risk Referrals.  Follow-up hemoglobin screening may be verbally refused by the participant. Documentation is required. • Infants o All infants will be screened between nine and eleven months (prior to first birthday) of age. o If an infant is applying for WIC and is about nine months or older at certification, a screening will be performed. • Children o A screening is required for all children at each certification.  If a one-year-old had a screening between nine and eleven months, the certification screening may be skipped. o Children will have a mid-certification screening  If under age 2 years; or  If their screening at certification was below the established cut-off value for anemia.  If this screening is missed; the child will be screened before benefits are issued.  Follow-up hemoglobin screening may be verbally refused by the participant. Documentation is required. o For children aged 2 and older, if the screening is at or above the established cut-off value for anemia at certification, no additional test is required for the certification period.  See Attachment Hemoglobin Reference Chart.  If below the cut-off, refer according to the High-Risk Referrals. • Exemptions:

o Participants may refuse to have a screening performed due to religious beliefs.  The applicant/participant or parent/guardian will write, sign and date a statement of refusal to have the screening performed for religious reasons or sign such a statement written by WIC staff.  The statement of refusal will be obtained at each visit when a screening would normally occur.  This document will be scanned into the participant’s folder. o Participants may be exempt from screening if they have a qualified medical condition (i.e., hemophilia, fragile bones, or a serious skin condition/disease) and appropriate documentation from their provider.  Written documentation from the provider will be signed and dated if hand­ written or be a printout from the medical record (via portal or EHR) and scanned into the participant’s folder.  If the condition is temporary, blood work should be obtained when the condition has resolved.  If the condition is chronic, the participant may be exempt from subsequent hematological requirements if medical documentation is valid.  Effort must be made to obtain hematological data from the medical provider if it is available. 5. Risk Codes • The CPA determines and documents all applicable nutritional risk codes after obtaining and evaluating the following information: o Demographic information o Current and past health data o Anthropometric and hematological measures, and o Category/age-appropriate nutrition assessment questions:  Diet/Nutrition status  Substance use  Supplement intake  Diagnosed medical conditions and medications  Other lifestyles behaviors which may impact social and/or physical health  Other relevant medical information • Self-report of a physician’s diagnosis. o A participant may self-report a medical condition that has been diagnosed by their healthcare provider. A self-reported medical diagnosis should prompt the CPA to validate the presence of the condition by asking more probing questions related to the self-reported professional diagnosis, such as:  Did a medical professional diagnose this condition?

 Is the condition being managed by a medical professional?  Can I please have the name and contact information for the medical professional to allow for communication? See Attachment Release of Information.  Is the condition being controlled by diet, medication, or other therapy? • Self-reporting “history of…” conditions should be treated in the same manner as self- reporting for current conditions requiring a healthcare provider’s diagnosis. o Self-diagnosis of a current or past condition should never be confused with self- reporting. o Although a risk may not be assigned based on a self-diagnosis (without medical diagnosis) it is appropriate for WIC staff to provide referral services to participants who report having symptoms so that a medical provider can confirm or rule out the presence of a medical condition. o Non-traditional health care providers such as shamans, medicine men or women, acupuncturists, chiropractors, or holistic health advisors are not considered to be physicians whose diagnosis can be accepted for establishing the eligibility of an applicant for WIC benefits. • Risk codes will be updated as necessary by staff during a certification period. o When a CPA assigned risk code is resolved, documentation will be made in the participant chart. o System assigned risk codes are automatically added or removed. • See Attachment Nutrition Risk Code Table. • See Attachment High-Risk Referrals. 6. Core Education Topics, Goal Setting and Nutrition Care Plans • Core Education Topics o Purpose and benefit of the WIC program (required at initial certification and additionally as needed):  WIC aims to improve health outcomes which include but are not limited to a healthy weight for pregnant women, infants and children, increased breastfeeding initiation and duration rates, reduced rates of iron-deficiency anemia, and improved nutritional status for all participants.  WIC provides nutrition education, referrals to healthcare/social services, and a food package specific to the participant category and need.  WIC eligibility is based on age/category, income, residence, and being at nutrition risk, which will be assessed by professional staff. o Food Package (required at each certification and additionally as needed):  Explanation of the food package available including substitutions and tailoring options available to the participant based on category, needs, and participant desires.

 Thorough explanation of how and where to use the benefits with local retailers.  Explaining supplemental nature of WIC program and other local resources for food. o Avoiding alcohol, tobacco, and drugs (required at each certification and additionally as needed):  Education on substance abuse must be provided to all participants and/or their caretakers and should address personal use as well as environmental exposure.  State developed substance abuse resource handout is required. o Rights and responsibilities (required at each certification):  Have participant read fully or offer to read them aloud, and sign that they understand. o If completing an appointment remotely, no signature is required. Staff must document authorized representative’s verbal acknowledgement of rights and responsibilities in the participant’s chart. o A copy of the rights and responsibilities should be provided to the participant via mail or electronic means.  The attachment WIC Memorandum of Understanding Disclaimer must be available for review by each authorized representative and/or participant when signing the Rights and Responsibilities. o If completing an appointment remotely, a copy of the MOU disclaimer should be provided to the participant via mail or electronic means. o Breastfeeding successfully (required at each certification):  For pregnant women this includes making an informed choice about the decision to breastfeed and exploring any barriers or questions.  For breastfeeding women this includes ensuring success based on mother’s stated goals or concerns. • Goal Setting o A participant-centered Specific, Measurable, Attainable, Realistic, and Timely (SMART) goal will be established with each participant at certification appointments. o Follow up on the goal will be documented at subsequent appointment(s). o If a participant declines to set a goal, document this in the participant folder. • Nutrition Care Plans o Nutrition care plans will be established at certification and mid-certification appointments for all participants.  RD will create plans for high-risk participants. o At a minimum the nutrition care plan will include:

 Time (if not the standard 3 months), follow up items (anthropometrics, bloodwork, etc.), and potential education for next appointment. 7. Referrals • Each applicant/participant will receive at least one referral at certification. If no appropriate referral is available, or is denied, document this in the participant record. • Participants with an identified high-risk code requiring a referral, will be referred according to the High-Risk Referrals table. o Participants with a risk code requiring referral to an RD, will be scheduled with the appropriate staff at the next appointment. The participant may decline high-risk referral which shall be documented in the participant’s chart. o Staff may request high-risk participants attend in-person subsequent appointments. • Infants and children 0-24 months of age that are not up to date with immunizations must be offered a referral to the local immunization program or to their primary care provider. o Being “up to date” for immunizations, for WIC purposes, includes having all 4 DTaP shots relatively close to the Centers for Disease Control (CDC) recommended schedule of 2, 4, 6 and 15-18 months of age. o The immunizations shall be verified by view of record.  The record may be brought in by the participant’s parent/caretaker, viewed electronically, or obtained from the Immunization program.  A participant may not be denied services if the record is not presented.  A participant may not be denied services if immunizations are not up to date and a referral is refused.  Documentation in the MIS of status is required. o WIC Staff are to coordinate with the local immunization program wherever possible. • At enrollment, authorized representatives for children will be asked if the child between 12-72 months of age has received blood lead testing at the recommended intervals of 12 and 24 months by any source (i.e., healthcare provider, Head Start), and/or 36 and 72 months. If the child has not had lead testing completed, a referral for testing will be made. o All children eligible for Medicaid are recommended for screening at 12 and 24 months of age, or at the earliest opportunity after this range if it is not completed. o WIC funds may not be used to purchase lead testing supplies or equipment; however, WIC is a vital contact point for young children at risk of lead exposure. Screening and education (i.e., iron and calcium intake, preventing lead exposure)

about the topic are within the scope of WIC services. See risk code 211 for more details. • All participants who are not currently enrolled in SNAP or FDPIR (if tribal), Medicaid, Healthy Montana Kids Plus (HMK plus), and/or TANF will be referred to these programs. o Early and Periodic Screening, Diagnostic and Treatment (EPSDT) information shall be made available to all families with infants and young children in written form. This information is included in the WIC Cardholder and Program Booklet. • Any household who identifies use of nicotine products will be referred to the Quitline, and other substance use programs as appropriate. o The WIC Cardholder and Program Booklet has the contact information included. • All participants or caretakers must be verbally educated about the risks of substance abuse/misuse. Written materials must also be provided (template for each geographic region is available from the State Office). All participants who identify substance use will be provided information on where to find treatment resources. • All participants who identify as being depressed, or have related mental health issues or symptoms, will be referred to local resource (or healthcare provider) for further screening, assessment and/or treatment. o This includes any ‘positive’ response from the Patient Health Questionnaire (PHQ)-2 included in the Nutrition Assessment Questions. • WIC referrals are “soft” referrals, meaning that we offer information about how to obtain the resource or service and then allow the participant to opt whether to follow through. WIC staff are not authorized to discuss the participant with the referral agency/program unless a release of information is signed, or a memorandum of understanding (MOU) has been executed at the State Level. The staff shall be familiar with the content of the MOU if this mechanism is used to share data with the program. • Under no circumstances should a participant be required to sign up for, or take part in, any other program. If other programs are offered to WIC participants, it shall be clear that they are optional and whether they opt into those services or not will have no impact on their WIC eligibility. • If a local agency provides a standard release of information to be signed at each certification (i.e., for the program to communicate with HCP or another program), this release shall be requested to be signed after the certification has been completed. 8. Nutrition Assessment Questions (NAQs) • Will be completed at each certification and mid-certification for appropriate category and age o Each question will have an answer.  Referral to another question(s) if the answer is previously stated is acceptable

o The Patient Health Question (PHQ)-2 for women and the food security questions and answer options for all families, will be stated as written when applicable.

Section II: Local Agency Procedure Manual VIII. Local Certification, Eligibility and Coordination C. Confidentiality and Service Coordination Purpose To ensure local agencies comply with federal regulations in the handling of confidential information. Policy Participant information will be kept confidential in accordance with federal regulations. The MT WIC Program will work with other health programs and services to promote administrative efficiency whenever possible. 1. Participant Information • Clinic staff are responsible to maintain applicant/participant confidentiality, this includes but is not limited to: o Ensuring verbal or written communication about participant’s information is private. For example: locking computers when away from desk; not discussing participants openly in clinic or in front of other participants or staff; keeping paperwork hidden from view; and not cross-referencing participant information in family charts. o Whenever possible, the local agency will provide separate rooms or private spaces for gathering participant information (income, weight, etc.) and individual counseling. The screening process for WIC eligibility is considered sensitive and privacy is critical. o Written communications with participants that include sensitive information (PII, PHI, etc) must occur through state-approved platforms. • Disclosure of participant information, whether provided by the applicant/participant or observed, is limited to: o Persons directly connected with the administration or enforcement of the Montana WIC program, such as WIC employees. o Representatives of public organizations designated by the chief health officer which administers health or welfare programs. ➢ The State WIC office will enter into a written agreement with each local agency. The agreement will contain a clause regarding understanding that the program will not disclose the information to a third party unless a Memorandum of Understanding (MOU) is in place. ➢ The WIC program may also have agreements in place on a national level, which will also be honored in the State of Montana. ➢ Entities that the Montana WIC program has MOUs with include: ❖ Supplemental Nutrition Assistance Program-Education (SNAP-Ed) ❖ Immunizations

❖ Maternal, Infant, and Early Childhood Home Visiting Program (MIECHV), also known as “Healthy Montana Families” (HMF) ❖ Census Bureau ❖ Child and Adult Care Food Program (CACFP) ❖ Medicaid, Supplemental Nutrition Assistance Program (SNAP), and the Temporary Assistance for Needy Families (TANF) programs, and ❖ The Pregnancy Risk Assessment Monitoring System (PRAMS) o MOUs* may include any or all the following purposes for the agreement, contact the State Office for details relating to the individual agreement: ➢ Establishing the eligibility of WIC applicants or participants for the programs that the organization administers. ➢ Conducting outreach to WIC applicants for such programs. ➢ Enhancing the health, education, or well-being of WIC applicants or participants who are currently enrolled for such programs. ➢ Streamlining administrative procedures. ➢ Assessing and evaluating the responsiveness of a state’s health system to participants’ health care needs and healthcare outcomes, and/or ➢ Share nutrition and health education materials. *The attachment WIC Memorandum of Understanding Disclaimer provides a summary of our current MOUs, whether personally identifiable information may be shared according to the MOU, and their overall purpose. This Disclaimer must be shown to the participant at the signing of the Rights and Responsibilities during each certification. o The Comptroller General of the United States for audit and examination authorized by law. • Suspected or Known Child Abuse o It is not the intent of this policy to prohibit or restrict the reporting of suspected or known child abuse or neglect. WIC staff are considered mandated reporters and must follow Montana State Law requiring the reporting of known or suspected child abuse or neglect. Providing all details pertinent to the report as requested is allowable. o All requests for information received from Child and Family Services, Child Protective Services, or other agency with the same intent, shall be sent to the State Director, or designee, for review and response. 2. Release Forms • Requests for applicants/participants to sign a Release of Information (ROI) will be limited to: o An applicant or participant request that information be sent to a third party or an organization (i.e. a doctor, insurance program, school nurse, job service, etc.). o Facilitating referral to another program. ➢ Signing such a release form may not be a condition of eligibility or participation.

o The participant must agree to a time limit on the release form. o Locally developed release forms may be used if they contain, at a minimum all the core elements as outlined in the WIC developed ROI. 3. Fax • Use of a facsimile (fax) machine can compromise the integrity of the medical record and lead to loss of participant confidentiality. The following guidelines apply to transferring participant information via fax. o Fax users at both ends of the transaction must know the proper procedures for the handling of confidential materials. o Fax only to and from machines located in secure or restricted access areas. o Transmit patient data by fax only when the original document or mail delivered copies will not serve. o Fax patient health care data only when the information is to be used for a participant care encounter. 4. E-Mail • Use of e-mail communication can compromise the integrity of a medical record and lead to the loss of patient confidentiality. E-mailed information is considered public record and is not secure; therefore, use of email with confidential and/or personal participant information is prohibited. 5. Volunteers • It is the responsibility of the local WIC program to exercise discretion in screening and selecting capable volunteers or interns who would have access to confidential information. • Once volunteers or interns are selected, specific confidentiality requirements governing the WIC Program must be covered in the orientation and training. Local programs will ask volunteers or interns to read and sign a confidentiality agreement. ➢ IT system access will only be provided to interns on a case-by-case basis. 6. Auditors • Official auditors from USDA Supplemental Food Programs, Montana Legislative Division, Department of Public Health and Human Services or those contracted and designated by the local program administration to assure fiscal integrity may have access to confidential participant information in the normal course of performing the review. • The audit report may not contain identifiable participant information. 7. Authorized Studies • Provide WIC information requested for an authorized study in a timely manner prior to the deadline or due date. • Local agencies may request assistance for information required to be submitted that is not available in their typical clinic processes. • Local agencies may request verification of an authorized study from the State WIC Office.

Section II: Local Agency Procedure Manual VIII. Local Certification, Eligibility and Coordination D. Participant Fraud, Abuse and Sanctions Purpose Maintaining program integrity ensures WIC Participants continue to receive program benefits. Policy The Montana WIC Program will implement appropriate sanctions when it is determined that a participant, caretaker, parent, authorized representative, or proxy is found to have committed an identified fraud/abuse of the Program. Standard procedures will be applied as described in this policy. 1. Participant Violations • Pursuant to 7 CFR 246.2, the definition of a participant violation is ‘any intentional action by a participant, parent or caretaker of an infant or child participant, or proxy, that violates Federal or State statutes, regulations, policies, or procedures governing the Program’ which includes the following: o Intentionally making false or misleading statements or intentionally misrepresenting, concealing, or withholding facts to obtain program benefits. o Dual participation, which is participating in and redeeming food benefits from 2 or more WIC programs, or Commodities Supplemental Food Program (CSFP) and WIC during the same time period. o Exchanging cash-value vouchers, food instruments or supplemental foods for cash, credit, non-food items, or unauthorized food items, including supplemental foods in excess of those listed on the participant’s food instrument (selling WIC benefits). o Threatening to harm or physically harming clinic, farmer, or vendor staff. o Sale, donation, exchange, or theft of WIC issued and owned multi-user breast pumps. o Stealing WIC benefits from a local WIC program or WIC participant. o Intentionally violating any aspect of program Rights and Responsibilities or policies. 2. Participant Sanctions • Mandatory disqualification for one year is required when the State: o Assesses a claim of $1,000 or more. o Assesses a claim for dual participation; or, o Assesses a second or subsequent claim for any amount. • Exceptions to mandatory disqualification include: o Full restitution or payment is made on a claim from the state by the participant or their caretaker within 30 days of receipt.

o A schedule or payment or restitution is agreed upon within 30 days of receipt of claim. o In the case of an infant, child, or participant under age 18, the State or Local Agency approves of a change in Authorized Representative. o A participant may re-apply to the Program prior to the 1-year timeline of disqualification if any of the above exceptions are implemented. o Dependent on the severity of the incident, the State may authorize the use of a ‘warning’ to a participant prior to implementing a sanction outlined here. • Sanctions for all violations, as determined by federal regulation or by the State WIC Program, are outlined in section 5 of this policy. • The local agency will follow procedures for handling complaints of fraud and abuse in collaboration with the State Office prior to taking any actions with a participant. 3. Procedures for handling complaints and/or detection of potential fraud and abuse by participants • Any WIC staff may accept complaints of potential fraud/abuse of any participant or their caretaker/representative or proxy. o The Program Complaint Form will be completed to document all information available and submit to the WIC State Office for review. All complaints will be initially followed up within three business days of receipt by the State Office. • The State Office, in collaboration with local staff, will perform standard and ad hoc review of charts, data reports, and online sites (e.g. social media) to validate the information provided. o If a fraud/abuse activity is detected through these means, staff will document the circumstance on the Program Compliance form and send to Program Integrity staff at the State Office. • Complaints will be thoroughly reviewed at the State Office. o All complaints will be logged for tracking purposes.  If a complaint contains any potential civil rights compliance issues, this complaint will be handled appropriately according to policy XI. Local Civil Rights/A. Civil Rights/Non-Discrimination and Complaints policy. o State Staff will review all available information to validate the complaint.  State staff may request assistance from local agency staff if further information is needed from the participant.  If certification data is in question, a review of the chart and all supporting documentation will be completed.  Issuance and redemption data will be reviewed to determine if a claim for repayment is necessary.

o Conclusions of the review will be documented by State staff on the log of complaints and on the Program Compliance Form.  Local Agency staff will receive the Program Compliance Form which will include instruction on next steps (warning/counseling or disqualification)  If a disqualification is necessary, the Notice of Ineligibility will be used; at least 15-days of benefits will be issued and then termination in the system will be effective.  All participants will be advised of their right to a Fair Hearing using this process.  If collection of intentional mis-used benefits, or re-payment for lost property (such as pump) is necessary, the State Office will initiate the claim.  The State Office will document on the Participant Compliance Form and scan into the participant chart and document in the Complaint log.  All participants will be advised of their right to a Fair Hearing using this process.  Claims for restitution (re-payment) will be paid by participant or responsible caretaker within 30 days of claim receipt.  A payment schedule may be agreed upon by the Participant/caretaker and the State Office.  If re-payment is not received within 30 days, and a payment schedule is not agreed upon, the State will pursue collections for all claims ≥$1,000.  Cost of contract formula will be considered based on net cost to the program after manufacturer rebate.

4. WIC Program Abuse and Sanctions (*required by federal regulation) Abuses Offense Sanctions Intentional misrepresentation of circumstances to obtain benefits*: • Misrepresentation of income, residence, identification, or family size. • Falsification of medical data or health status. • Misrepresentation of actual date of birth to appear to be categorically eligible, or to go undetected as a dual participant. 1st 2nd Warning/Educational Counseling will be conducted if the incident did not result in mis-used benefits (redemption) Three-month disqualification from the WIC program if claim for benefits mis-used is <$1,000; or Twelve­ month disqualification from the WIC program if claim for benefits mis-used is ≥$1,000*; and re-payment of mis­ used benefits* Twelve-month disqualification from the WIC program for any second or subsequent claim made on intentionally mis-used benefits* and re-payment for benefits mis-used* Dual Participation* 1st Twelve-month disqualification Receipt of, or attempt to receive, cash or credit toward unauthorized food or other item of value in lieu of authorized supplemental foods from a retailer* 1st 2nd Education & Warning Letter Twelve-month disqualification Threatening to harm or physically harming clinic, farmer or vendor staff* 1st Twelve-month disqualification Attempt to sell, sale or donation or exchange of WIC issued and owned multi­ user breast pumps Any Warning/Educational Counseling will be conducted if the incident did not result in loss of property Re-payment of value of pump(<$1,000) to the WIC program within 30 days of claim Local Agency report to law enforcement

Abuses Offense Sanctions Verbal abuse or harassment of clinic, farmer, or vendor staff 1st 2nd Education and warning letter (change of retailer/authorized representative/proxy may also be appropriate) Twelve-month disqualification

Section II: Local Agency Procedure Manual VIII. Local Certification, Eligibility and Coordination E. Verification of Certification (VOC) Purpose To provide guidance for local agencies to apply appropriate VOC/transfer procedures. Policy The Montana state WIC program will issue a VOC to each participant who is a member of a family in which there is a migrant farm worker or any other participant who is relocating during the certification period. 1. VOC Documentation • Used for WIC participants transferring from one state to another or from an overseas program. • Is equivalent to a WIC certification and will be used until the end of the current certification period documented on the VOC, which will be entered the WIC MIS as the last day of that month. o If the participant was in a current certification period prior to leaving Montana and the VOC document from the transferring state has a shorter end of certification period, use the end of the certification period that is longer. • If the local agency is at maximum caseload and has a waiting list for participation, transferring participants with a valid VOC will be placed at the top of the list regardless of priority. 2. Issuance of VOC Documentation • The clinic will issue one VOC document to each participant who is identified as a migrant at each appointment, or any participant who intends to transfer out-of-state. All VOC documentation contains the following information: o Participant’s name. o WIC Participant’s ID Number. o Date participant was certified. o Date income eligibility was last determined. o Nutrition risk condition of the participant. o Date current certification expires. o Dates through which benefits are issued. o Name and address of certifying local agency. o Name and signature of certifying local agency official. 3. Acceptance of VOC Documentation • The following minimum information on the VOC documentation is required: o Participant’s name.

o Date the participant was certified. o Date current certification expires. • The VOC documentation will be scanned into the applicant’s/participant’s folder. • If a participant transferring from another state brings in benefits from that state, local agency staff will collect previously issued benefits (cards or checks), and reissue Montana state WIC benefits for the same benefit period. Checks can then be destroyed. o For eWIC cards, contact the issuing agency to confirm the benefit balance, and to request they void any remaining benefits. The receiving agency should then destroy the card, if presented. o If a participant transfers with a VOC that shows benefits (checks) were issued, but doesn’t have them in possession, the receiving agency must contact the issuing agency to report the lost/missing checks and obtain balance information for issuance. o If you cannot reach a representative at the issuing agency, do not re-issue current benefits, but you can re-issue future benefits. Follow up with the issuing agency to request that they void future benefits.  If local agency contact information is not on the VOC document, or you’re unable to get through to the clinic, you may contact the number listed on the FNS website (http://www.fns.usda.gov/wic/wic-contacts ). • Identification and residency will be obtained for participants transferring from one state to another. • Enter as much information about the participant as available. o Complete demographics and health history if possible, during normal scope of appointment. o Clinic does not need to re-create all the information in the certification to transfer in a VOC participant. o Staff will enter all applicable risk codes from the VOC into the chart. • Scheduling appointments depends on where the participant is in their current certification. o For example, if they are 3 months into their certification, schedule their appointment as a follow up. 4. WIC Military Overseas Program • Clinics will accept a valid WIC Overseas Program VOC document from the participant returning to the U.S. from an overseas assignment. • Clinics will issue VOC documentation to WIC participants affiliated with the military who will be transferred overseas. o WIC participants issued VOC documentation when they transfer overseas will be instructed as follows:

 There is no guarantee the WIC Overseas Program will be operational at the overseas site where they will be transferred.  By law, through the Department of Defense, only certain individuals are eligible for the WIC Overseas Program.  Issuance of WIC VOC Documentation does not guarantee continued eligibility and participation in the WIC Overseas Program.

Section II: Local Agency Procedure Manual VIII. Local Certification, Eligibility and Coordination F. Notification of Ineligibility and End of Certification Purpose To provide guidance to local agencies to apply appropriate notification of ineligibility and end of certification procedures. Policy Participants found ineligible for the Montana WIC program during a certification will be advised in writing of their ineligibility. Each participant, parent, or caregiver will be notified not less than 15 days before the expiration of each certification period, that certification for the program is about to expire. 1. Notification of Ineligibility • An applicant/participant is determined ineligible for one of the following reasons: o If a certification is shortened due to a category change, such as the discontinuation of breastfeeding after 6 months for a woman. o Applicant/participant does not meet income guidelines.  Scan income documentation into the applicant/participant folder to support a Fair Hearings claim. o Shows no nutritional risk, and/or o The participant commits fraud and is terminated from the program based on the criteria outlined in the Participant Fraud, Abuse and Sanctions policy. • If applicant/participant is found ineligible: o Generate the proper Notice of Ineligibility.  If the automated form is used, it will show in the notes section and does not need to be scanned into the participant folder.  If the non-automated End of Certification and Notice of Ineligibility Form is used, a copy will be scanned into the applicant’s/participant’s folder.  This notice includes the reason for disqualification, the non-discrimination statement, and the fair hearings procedure.  Prior to system termination, the participant will be provided benefits for 15 days, unless the reason for termination is a change in categorical eligibility, or they no longer reside in the state. • Local WIC clinics will provide information about other potential sources of local food assistance. 2. End of Certification Notice • All participants will be issued the End of Certification notice at least 15 days prior to their certification end date, or when their last set of WIC benefits are issued (if greater than 15 days from their certification end date).

o If the automated form is used, it will show in the notes section and does not need to be scanned into the participant folder. o If the non-automated End of Certification and Notice of Ineligibility Form is used, a copy will be scanned into the applicant’s/participant’s folder. o If a verbal notification of end of certification is given, it will be documented in the MIS notes. o If the participant’s shopping list (available balance) or cardholder is used as notice, it must be documented in the participant’s folder. • Participants will be provided a food package to cover the 15-day time period. o If the system terminates for non-participation, the End of Certification/Notice of ineligibility does not need to be sent. 3. Office of Fair Hearings • The Office of Fair Hearings is part of the Department of Health and Human Services (DPHHS) Office of Administrative Hearings. They are located at PO Box 202922, Helena, MT 59620, and their contact phone number is (406) 444-2470, or email hhsofh@mt.gov.

Section II: Local Agency Procedure Manual VIII. Local Certification, Eligibility and Coordination G. Fair Hearings Purpose Participants and vendors may request a fair hearing because of an adverse action by the program. Policy The WIC Program has defined procedures for individuals that request an administrative review of adverse actions. 1. Fair Hearing Procedure • A fair hearing procedure will be conducted for any entity who appeals a State or local agency action which results in a claim against the individual for: o Repayment of the cash value of improperly issued and/or redeemed benefits. o An action that results in the individual’s disqualification from the WIC Program. 2. State Responsibilities • All requested fair hearings will be conducted by DPHHS within three weeks of the date the Department received the request for a hearing. o Those requesting the hearing will be notified in writing a minimum of ten (10) days in advance of the time and place of the hearing and of the hearing procedure. • The hearing will be conducted in accordance with 7 CFR 246.9 and Title 2, Chapter 4 of the Montana Code Annotated. • The hearing will be conducted by a fair and impartial hearing official and the appellant will be notified in writing of the decision of the hearing official, and reasons for it, within 45 days of the receipt of the request for a fair hearing. • All decisions will be based on facts found in the hearing record, and the parties will be notified of their right to appeal the decision to District Court within 15 days. • The hearing official’s decision is binding on the State WIC Office and local agency. o If in favor of the appellant, program benefits will begin for an applicant and continue for a participant within the 45-day limit. o If the decision is in favor of the appellant and benefits were denied or discontinued, benefits will begin immediately. o If the decision concerns disqualification and is in favor of the local agency, the local agency will terminate any continued benefits, as determined by the hearing official. o If the decision regarding repayment of benefits by the appellant is in favor of the local agency or the State WIC Office, these entities will resume their efforts to

collect the claim, even during pendency of an appeal of a local-level fair hearing decision to the State WIC Office. • All records of the hearing will be retained in accordance with 7 CFR 246.18 and 7 CFR 246.25, and will be available to the appellant or representative. 3. Local Agency Responsibilities • Inform each program applicant or participant of their fair hearing rights at initial and subsequent certifications. o Advise them of the method for requesting the hearing and a summary of the fair hearing process. o Their right to be represented at the hearing by a relative, friend, legal advisor, or other representative of their choice. • Appeal rights are provided at the time of a claim for repayment of the cash value of improperly issued and redeemed benefits or denial of participation or disqualification. o Notification will be made to the participant a minimum of 15 days prior to termination of program benefits or expiration of each certification period that the period is about to end.  Attachment End of Certification/Notice of Ineligibility will be used to communicate this information. o Applicants/Participants found ineligible due to fraud and/or abuse will have:  Documentation of the ineligibility will be kept in their chart.  Applicants who are denied benefits at initial or subsequent certifications will not receive benefits while awaiting the hearing.  Participants who become categorically ineligible during a certification period will not receive benefits while awaiting a hearing and results.  Applicants/Participants found ineligible have up to 60 days from notification of ineligibility to request a fair hearing from the Montana Department of Public Health and Human Services (DPHHS).  The request for hearing is defined as any clear expression by the individual, guardian or other representative that an opportunity to present its case to a higher authority is desired.  Local agencies should obtain legal counsel to represent the WIC program if a hearing is requested.  If a hearing is requested at any time during a certification period benefits will be continued or reinstated until:  A decision is reached in accordance with 7 CFR 246.9; or,  The certification period expires o Each participant found ineligible at any time during a certification period for reasons of fraud or abuse will have:

 Documentation kept in their chart to include:  The person against whom the collection of improperly issued benefits is undertaken.  Reason(s) for the claim.  The value of the improperly issued benefits.  Notification of their right to a fair hearing.  Attachment End of Certification/Notice of Ineligibility will be used to communicate this information. • A request for hearing will be dismissed or denied if: o It is not received within 60 days from notification of ineligibility; o The request is withdrawn in writing by the appellant; the appellant or appellant’s representative fails, without good cause, to appear at the scheduled hearing; o The appellant has been denied participation by a previous hearing and cannot provide evidence that circumstances relevant to program eligibility have changed in such a way as to justify a hearing. 4. Time Sequence for Fair Hearings Step Participant State/Local Agency Participant is notified of ineligibility for WIC benefits. Has 60 days to request a fair hearing. * Local Agency must provide participant with Notice of Ineligibility and follow procedures outlined in WIC State Plan. Participant requests a fair hearing to the State WIC Agency within 60 days. Will receive 10 days written notice of time and place of the fair hearing within 3 weeks of request. Local Agency obtains legal counsel to represent the WIC program at the hearing within 3 working days of receipt of the hearing request. Fair hearing is held in the county where the participant resides. Will receive the decision of the hearing official within 45 days of the original request. Within 45 days the State WIC Office sends the participant the decision of the hearing official. Participant appeals decision. Request must be made to the District Court within 15 days of receipt of written notification of the decision. State WIC Office notifies Legal Division of appeals request. *The participant who is terminated during a certification period and requests a fair hearing within 60 days of termination will continue receiving benefits until a hearing decision is made or the certification period expires. Applicants denied at certification, participants who

become categorically ineligible during a certification period or whose certification period expires will not receive benefits while awaiting a hearing and results.

Section II: Local Agency Procedure Manual XI. Local Civil Rights A. Civil Rights/Non-discrimination and Complaints Purpose To ensure that the Montana WIC Program does not discriminate based on the protected classes identified by USDA FNS and the State of Montana. Policy The local agency will comply with Title VI of the Civil Rights Act of 1964, Title IX of the Education Amendments of 1972, Section 504 of the Rehabilitation Act of 1973, the Age Discrimination Act of 1975, 7 CFR Parts 1, 15a, 15b, FNS Instructions and MCA 49-2-303. 1. Public Notification • The State WIC Office and all local agencies will provide information regarding the availability of benefits and WIC’s eligibility criteria with emphasis on pregnant women, migrants and homeless individuals. Agencies and private groups serving vulnerable populations are included in the outreach and referral network. This information will always be available on the Montana WIC website. • If applicable, special outreach efforts will be made to inform migrants of the availability of the program. Outreach and referral activities are monitored by the State WIC Office staff during the on-site biennial monitoring visit, and in the annual review of the local outreach plan. • All local agencies will have the following posters displayed wherever eligibility is being determined and wherever benefits are issued: o “And Justice for All” o “Fair Hearings Procedure” o Point to Your Language poster • Other required postings in the clinic include: o Office Hours o Statement that the facility is “Non-Smoking” o WIC Memorandum of Understanding (MOU) Disclaimer o Any policy that impacts participant access or services • Fair hearing and discrimination complaint procedures are provided in writing to participants when they are determined ineligible for the program. • Local agencies will communicate any changes in hours of operation or hours of new sites to the State WIC Office, and post for applicants and participants to easily view. 2. Non-Discrimination Statement for WIC Materials • The non-discrimination statement must be included on any programmatic materials which provide information on WIC eligibility or services, which includes, but is not limited to: o Notice of Ineligibility o Program Booklet o Rights and Responsibilities

o WIC brochures o Any outreach materials o Press releases or Public Service Announcements o WIC Vendor agreements o Farmer’s Market Nutrition Program (FMNP) agreements o Contracts to provide WIC services The non-discrimination statement is: 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/USDA-OASCR%20P-Complaint-Form-0508- 0002-508-11-28-17Fax2Mail.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. 3. Permitted use of Abbreviated Statement • Requirements from the 113 FNS-Instruction state that if the written material or short forms are too small to permit the full statement to be included, the material will at a minimum include (in print size no smaller than the text)“This institution is an equal opportunity provider” 4. Bilingual Staff, Qualified Interpreters, and Materials • Local agencies will ensure required WIC services are provided to non-English or limited-English speaking persons in the appropriate language. This includes arranging for interpretive services as needed or requested by the participant.

o Participants may choose to bring a friend or family member to interpret for them; but under no circumstance will a participant be required to do so. o A minor may not be used for interpretation under any circumstances. • Language interpretation services are available through the State Department of Public Health and Human Services (DPHHS) for all WIC clinics to use. A separate agreement is not necessary at each local agency. o See attachment Language Link Interpretive Services for instructions on use o See attachment Point to Your Language poster to be posted at the point of service for any applicant or participant to use in requesting language interpretation services. • The local agency will ensure that all applicable rights and responsibilities are read to non-English and limited-English speaking participants or parents/guardians of applicants/participants in the appropriate language. • All interpreters will comply with confidentiality regulations. o A minor may not be used for interpretation under any circumstances. • 711 Montana telephone relay service is a free service that connects customers who are deaf, hard of hearing or have speech disabilities. o This service will be provided to applicants/participants during all WIC services. o To access this service in Montana dial: 1-866-253-4090 (English); 1-866-225-1866 (Spanish). o Participants are not required to provide their own interpreters although they may voluntarily choose to bring a friend or family member to interpret if they prefer. 5. Provision of Services • For each local agency that has sites not accessible to persons with disabilities, a written local policy will be developed to describe how services will be provided to the participant. o These provisions may include:  Service at other clinic sites  Within other accessible locations within the same clinic o In choosing among available methods, the local agency will give priority to methods that offer the most integrated setting appropriate for disabled persons to obtain the full benefits of the program. o The local policy will be flexible enough to provide reasonable accommodations to cover all types of disabilities. o These provisions may include:  Interpreters for the deaf  Readers of Braille for individuals who are visually impaired • The intent of the Americans with Disabilities Act (ADA) is for people with disabilities to receive information in the form they prefer. o Examples of formats preferred by persons with disabilities include:  Large print  Audio compact discs  Captioned videos  Braille text o Information in alternate form

 A person who is hearing impaired may request that a nutrition education lesson be provided in another form, such as a pamphlet. o Undue hardship  Undue hardship is an action requiring significant difficulty or expense when considered considering factors such as employer’s size, financial resources, and the nature and structure of its operation.  The Montana Department of Public Health and Human Services, as a governmental entity of the state of Montana, is obliged in almost all circumstances to honor requests for accessible materials. Inconvenience or moderate difficulty or expense is not a sufficient reason for failing to provide all program related information in the form desired by the disabled person requiring it.  If it may be demonstrated that providing information in a particular format would impose an undue hardship, it need not be provided in that form.  Contact the State WIC Office for approval to deny a request based on undue hardship. When possible, the State Office will assist in producing requested materials. 6. Civil Rights Training and Compliance • All new employees must complete civil rights training prior to receiving access to the WIC automated system. Thereafter, annual training is required by all employees during the federal fiscal year. The following are required annual civil rights training topics: o Collection and use of racial/ethnic data o Effective public notification systems o Complaint procedures o Compliance review techniques o Resolution of non-compliance o Requirements for reasonable accommodation of persons with disabilities o Requirements for language assistance o Verification of citizenship and immigration status o Conflict resolution o Customer service • During biennial on-site visits State WIC Office staff will monitor for civil rights policy compliance. If non-compliance is found, a corrective action plan is required to remedy the deficiency. • All findings of non-compliance or probable non-compliance related to Title VI will be forwarded to the Regional Administrator in the Mountain Plains Regional Office. 7. Reviews of Potential Programs • As part of the application review process, State WIC Office staff will review applications according to the federally outlined criteria. 8. Civil Rights Impact Analysis • Local Agency staff must complete an impact analysis before opening, relocating, or closing any clinic site including satellite facilities. See Attachment Civil Rights Impact Analysis. • This form must be submitted to the State WIC office 30 days prior to opening, relocating, or closing a clinic site or satellite facility. • The local agency shall assure the continuity of WIC Services is addressed in their local agency emergency response/disaster preparedness plan (ERDP). The guidelines shall reflect the purpose, authority and responsibilities developed locally.

9. Civil Rights Complaints • Local agencies will use the Program Complaint Form to record any complaint, including those from an individual who feels their civil rights may have been violated. o Civil Rights violations include any form of discrimination based on race, creed, religion, sex, culture, color, age, physical or mental disability, veteran status, genetic information, national origin, sexual orientation, social origin or condition, retaliation, political belief, marital status, or ancestry. • If the complainant declines to submit allegations in written form, the person receiving the call will write up the elements of the complaint by attempting to obtain as much information as possible. o Name, address, telephone number or means of contacting the complainant. o Specific location and name of the State or local agency delivering the service or benefits, or retailer where benefits were redeemed o The nature of the incident or action that led the complainant to feel discrimination was a factor. o The basis on which the complainant believes discrimination exists. (i.e. race, color, national origin, age, disability, sex, or retaliation or reprisal in any program or activity conducted or funded by USDA.). o Names, titles, business or personal addresses, telephone numbers of persons who may have knowledge of the alleged discriminatory action. o The date(s) during which the alleged discriminatory actions occurred, if continuing, the duration of such actions. In cases where the Local Agency staff are sure no discrimination based on a protected class has occurred, they will follow up using the Montana WIC Compliance Form. o In cases where discrimination may have occurred, Local Agency staff will refer the Program Complaint Form to the State WIC Director. All Civil Rights complaints must be submitted immediately. o A full record of all activities related to the complaint will be maintained on file, and logged, in the receiving agency’s office. If the complaint is received at the State Office, a copy will be provided to the Local Agency.  These records will be reviewed during routine monitoring visits. • After review, the State WIC Office will determine if the complaint constitutes a Civil Rights violation, and if so, will immediately refer in writing such complaints to the National Office of the Assistant Secretary for Civil Rights and the Montana DPHHS Office of Human Resources Civil Rights/EEO Specialist for investigation. • Any person or representative alleging discrimination has the right report the complaint on their own and to file a complaint within 180 days following the alleged incident, and may choose to report the incident to any of the following entities: Montana WIC Director USF&G Basement 1625 11th Ave PO Box 4210 Helena, MT 59604-4210

Phone: 1-800-433-4298 Fax: (406) 444-0239 OR USDA Office of the Assistant Secretary for Civil Rights 1400 Independence Ave, SW, Stop 9410 Washington, D.C. 20250-9410 Local area: (202) 260-1026 Toll-free: (866) 632-9992 Local or Federal relay: (800) 877-8339 Spanish relay: (800) 845-6136Fax: 1-833-256-1665 OR Montana Department of Public Health and Human Services Office of Human Resources Civil Rights / EEO Specialist 111 N. Sanders St. Helena, MT 59604-4210 Phone: (406) 444-1386 Fax: (406) 444-0262 • Complaints against Local Agency staff received by the State WIC Office will not be communicated to the Local Agency for the State or USDA to determine whether an investigation is necessary. • Confidentiality of the individual making the civil rights complaint will be maintained throughout the process. o The identity of every complainant will be kept confidential except to carry out an investigation, hearing, or judicial proceeding. o Anonymous complaints will be accepted and handled as any other complaint. • All Civil Rights Complaints will be placed into the local agency Civil Rights log for tracking purposes. 10. Examples of Discrimination • Exclusion of eligible persons from participation in the program on the basis of race, color, national origin, age, sex, disability, and retaliation or reprisal in any program or activity conducted or funded by USDA. • Unfair allocation of food to eligible persons based on race, color, national origin, age, sex, disability, and retaliation or reprisal in any program or activity conducted or funded by USDA. • Issuance of food benefits or delivery of foods 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, disability, and retaliation or reprisal in any program or activity conducted or funded by USDA. • Selection of local agencies for participation in the program which has the effect of, or results in, limiting the availability of the program benefits or services on the basis of race, color, national origin, sex, age, disability, and retaliation or reprisal in any program or activity conducted or funded by USDA. • Failure to apply the same eligibility criteria to all potential participants seeking participation in the program on the basis of race, color, national origin, age sex, or disability, and retaliation or reprisal in any program or activity conducted or funded by USDA. • Certification of potential participants to receive program benefits solely based on race, color, national origin, age, sex, disability and retaliation or reprisal in any program or activity conducted or funded by USDA.

• Maintenance of a waiting list which makes distinctions based on race, color, national origin, age, sex, disability, and retaliation/reprisal in any program or activity conducted or funded by USDA.

Section II: Local Agency Procedure Manual XI. Local Civil Rights B. Barriers to Providing Services Purpose To provide guidance to Local Agencies in removing barriers to WIC services. Policy WIC program services will be accessible to all applicants and participants. 1. Barriers to Service Access to services and customer service is a priority of the Montana WIC Program. Barriers to apply and participate should be reduced or eliminated when possible. 2. Administrative Barriers New staff receive training on customer service, civil rights, and the goals and purpose of the WIC Program. To improve access and customer service: • WIC staff must make every reasonable effort to have someone available to answer incoming calls during clinic hours. When someone is not available, a voicemail system must be in place. • Receiving WIC services during standard business hours can be a barrier. WIC Staff are encouraged to make reasonable efforts to provide services outside of standard business hours. • Remote issuance of multiple months benefits and coordinating WIC appointments with other programs is encouraged. • If a participant does not speak English or has Limited English Proficiency (LEP), access to interpretive services is required. Anyone with another communication impairment must be accommodated to reasonable standards and in line with the American with Disabilities Act. 3. Physical Barriers • Easy access to the clinic by pregnant women and those participants with physical disabilities is critical to providing WIC services. • Staff must ensure that the clinic layout can provide a private space to discuss the confidential topics in a WIC appointment, if requested by the participant or deemed necessary by WIC staff. • WIC staff must make reasonable efforts to modify procedures to serve applicants/participants who cannot physically come to the clinic. This may include providing services in a more private or more accessible off-site location, providing services through remote communication technology (confidential and secure), or by coordinating services with healthcare providers, or other programs WIC is associated with (such as Home Visiting and Immunizations). 4. Federal Regulations The following is adapted from “Information and Technical Assistance on the Americans with Disabilities Act, Title III: Public Accommodations and Commercial Facilities.” • The Montana WIC Program will provide services in an integrated setting, unless separate or different measures are necessary to ensure equal opportunity. WIC will eliminate unnecessary

eligibility standards or rules that deny individuals with disabilities an equal opportunity to use WIC services. WIC will make reasonable modifications in policies, practices and procedures that deny equal access to individuals with disabilities. • Safety requirements may be imposed only if they are necessary for the safety of the applicant/participant. They must be based on actual risks and not on mere speculation, stereotypes, or generalizations about individuals with disabilities. • Examples of modifications to remove barriers include installing ramps, making curb cuts at sidewalks and entrances, rearranging tables, chairs, display racks and other furniture, widening doorways, installing grab bars in toilet stalls, arranging for the services of a person familiar with sign language to assist in serving deaf applicants/participants, and/or adding raised letters or Braille to elevator control buttons. • Based on the Americans with Disabilities Act’s accessibility guidelines for new construction and alterations, relocation, WIC clinics must be in sites with: o Van accessible parking o Accessible routes o Ramps, stairs, elevators o Doors, entrances o Bathrooms, alarms, signs, and fixed seating • The public or common use bathroom must be accessible and in good working order.

Section II: Local Agency Procedure Manual XI. Local Civil Rights C. Collection of Race/Ethnicity Data Purpose To ensure race and ethnicity data is collected to be used by United States Department of Agriculture (USDA) Food and Nutrition Service (FNS) to determine how effectively the Program is reaching minority groups and identify areas where additional outreach is needed. FNS may use this de-identified data for statistical purposes. Policy The local agency staff will collect participation data by race and ethnicity category for each participant on the program at certification. 1. Collection • Local agencies will ensure participation data by category of women, infants and children is recorded by race and ethnicity category. • This information will be collected and entered into the Montana WIC MIS. 2. Participants will be reported in one or more racial categories which include: • American Indian or Alaskan Native - A person having origins in any of the original peoples of North, South, or Central America and who maintains tribal affiliation or community attachments. • Asian - A person having origins in any of the original peoples of the Far East, Southeastern Asian or Cambodia, China, India, Japan, Korea, Malaysia, Pakistan, the Philippine Islands, Thailand and Vietnam. • Black or African American - A person having origins in any of the black racial groups of Africa. • Native Hawaiian or other Pacific Islander - A person having origins in any of the original peoples of Hawaii, Guam, Samoa, or other Pacific Islands. • White – A person having origins in any of the original peoples of Europe, Middle East, or North Africa. 3. Participants will be reported in only one ethnic category which include: • Hispanic or Latino - A person of Cuban, Mexican, Puerto Rican, South or Central American or other Spanish culture or origin regardless of race can be used under the title of “Hispanic or Latino”. • Non-Hispanic or Latino. 4. Self-identification • At the time of certification, self-identification by the participant must be requested. o After racial and ethnicity groups have been explained, participants will be asked to self- identify their race and ethnicity.

 Local agency staff will notify participants that the collection of this information is strictly for statistical reporting requirements and does not affect program eligibility determination. 5. Participant Chooses Not to Self-identify • Local agency staff will notify participants that choose not to self-identify that a visual identification will be used to determine the participant’s racial and ethnicity categories. o Selection of one race is acceptable when local agency staff performs visual identification. 6. Analysis • This data will be used by the United States Department of Agriculture (USDA) and the State WIC Office to monitor compliance with civil rights laws and to determine how effectively the Program is reaching minority groups. o Data may help identify areas where additional outreach is needed. o Data may help identify health disparities among WIC participants when reviewing statistical data.

Section II: Local Agency Procedure Manual IX. Local Food Delivery A. Issuing/Replacing Benefits Purpose Provide guidance on benefit issuance and replacement. Policy Local WIC Staff will issue appropriate benefits to all eligible participants according to this policy. 1. Benefit Issuance  The CPA determines how many months’ worth of benefits a participant receives. o Issuing three months of benefits is recommended for most participants. o More frequent issuance (unless for the purpose of aligning family members) implies the participant has greater education needs. Documentation of reason for more frequent issuance, as well as education provided, will be made in the chart for each issuance.  Benefits are issued “month to month”, starting on the first day and ending on the last day of the calendar month. o Some benefits may be prorated based on the timing of issuance during the month by three-quarters, half, or one-quarter.  Clinic staff may provide the full food package (“un-prorate”) at their discretion in the following circumstances:  If the reason for late issuance was related to a clinic issue, rather than a participant issue (i.e. missing appointments, or opting to start on the program later in the month). Examples of this may include the inability of the clinic to find an appointment time early in the month; clinic being short staffed and needing to reschedule participants; or a technical problem that prevented issuance correctly.  Documentation in the chart for reasoning of providing the full package rather than the prorated package is required.Only the participant or their authorized representative may complete an appointment on behalf of the participant.  Local agency staff will review benefits for accuracy with the participant/authorized representative prior to sending EBT data to processor.  Issuance of benefits prior to completion of program requirements is prohibited. 2. eWIC Card Issuance/Replacement

 Only one eWIC card will be issued per household. o Each household will have one designated primary cardholder, who will also be listed as an authorized representative (primary or alternate). The primary authorized representative is ultimately responsible for program compliance, and therefore will determine who will be assigned primary cardholder. They may change this designation at any time.  Only the primary authorized representative can request card replacements. Secondary authorized representatives can pick up and sign for the card after the primary provides verbal or written request. o A foster child is a household of one. Each foster child must have their own eWIC card, to be managed by their authorized representative (in most cases the foster parent).  Local agency staff will instruct the participant/authorized representative on setting a personal identification number (PIN) for the card, and ensure they understand redemption procedures.  Lost, damaged or stolen eWIC cards may be replaced by the local agency (preferred), or by contacting Solutran at (844) 583-3237, or online at www.mybnft.com. Solutran replacements will be processed within 24 hours, however they will be sent using ground shipping. o When the clinic is replacing an eWIC card, documentation of the reason for the replacement will be made in every household member chart.  If a trend within an agency is observed by the State Office, a conference call may be set up with local agency staff.  The State staff may request local staff to educate participants about card care when replacements are excessive.  Replaced cards will have the same PIN number, if a change is desired, the primary cardholder is responsible for this. o If the card is being mailed from the local agency, it is required to document this on the eWIC Card Inventory Log. Mailing must be certified (“Do not forward/Return to Sender” on envelope), and the signed certified card will be scanned into the chart. If the signed card is not received in a reasonable amount of time, contact should be made to determine next steps for ensuring the participant receives their card.  If a card is found and returned to the clinic: o Review the account and contact the primary cardholder. If it is still active, and cannot be immediately returned to the cardholder, deactivate the card and documentation of circumstance will be made in the chart. o The participant/authorized representative will be responsible to request a new card. 3. Over-Issuance

 An over-issuance is any instance where more than the maximum allowable WIC benefits are issued for a benefit period.  The local agency or participant may be responsible for any fund’s mis-spent due to over- issuance. The State Office may require these funds to be re-paid. o Reimbursement will be made to the State Office within 30 days of receipt of this invoice. o Payment of the funds may not be made from the WIC funding source in the contract for local agency restitution. o The participant, or their caretaker, may be responsible to repay mis-used benefits per policy, “D. Participant Fraud, Abuse and Sanctions” in section II, VII. Certification, Eligibility and Coordination. 4. Remote-Issuance • Benefits may be loaded remotely at the discretion of the local agency staff when program requirements have been met by the participant. o If a nutrition education appointment is scheduled and missed, the agency may load up to three months benefits with appropriate documentation. The subsequent appointment must be attended for additional months to be issued. o Communication with the participant is required, including a plan for the next appointment (if applicable), and a notification to the participant of why the benefits are being loaded. 5. Food Package Changes Within a Benefit Cycle  Changing a food item or updating a food package may be done at the participant’s request (i.e. new medical prescription received, or breastfeeding amount change reported). o Where possible, it is ideal to start the new package on the following month, as any current redemption could complicate issuance of a new current food package. o Issuance shall be prorated based on redemption in current month where possible.  Breastfeeding amount changes in a current month may affect both food packages in the dyad. o The mother shall keep her current month benefits. o The infant will receive the appropriate benefit for the current month (where possible). o Future months shall reflect updated status and correct package for both mother (if applicable) and infant. o If the mother has changed from breastfeeding to non-breastfeeding, she will be notified of her end of certification date (to be documented in chart) or be provided the End of Certification/Notice of Ineligibility, dependent of where she is in the post­ partum period.

 Adjusting formula benefits mid-month will prompt the system to update current benefits. Future benefits can be updated by clicking the applicable button on the adjust benefits screen.  Local agency staff shall NOT void current benefits to make food package changes. 6. Foster/Kinship Placement or Legal Custody Changes  In any situation where an infant/child has a legal custody change, the WIC staff must move the child’s household, and re-issue benefits appropriately (may be prorated, or fully issued based on the situation and timing in the month). Legal paperwork must be scanned into the participant file to allow for any household changes in this situation.  If an infant or child is legally in the custody of the State (Child and Family Services), or Tribal authorities, they are considered a foster child and will need to be placed in a household of “1”. When this happens during a current certification, benefits need to be voided in current household, and re-issued (in full, at staff discretion) via the new caretaker/foster home authorized representative. Placement paperwork that has been provided to the caretaker of the foster infant/child must be scanned into the chart. o This paperwork must have enough information to determine that legal placement is with the authority, whom the current caretaker is, and must include:  Caretaker’s name  Date of Placement  Infant/Child name and Date of Birth o Caretaker relationship to the child (i.e. licensed home vs. family member) is not a determinant of minor’s status as a “foster child”, and hence a family of “1” for WIC purposes.  If the infant/child was removed from a home with current participants certified (others in that household with valid benefits), that card shall not be de-activated. o If no redemption for the infant/child has happened in the current month, then all current and future benefits may be voided for that infant/child prior to using change household guided script. o If some redemption has occurred for this participant, only void future benefits and written notification to the authorized representative listed in the household to let them know they shall not use any more of the benefits related to the infant/child who is no longer in their custody.  Documentation of this communication shall be made in the participant folder.  If redemption occurs after verified communication takes place, this must be reported to the State Office for investigation and potential restitution of benefits.

 A new card will be issued for the infant/child in the new household of “1”, with current (may be prorated if deemed appropriate by staff) and future benefits loaded onto the card. o If any errors are encountered in the process of changing households or removing/replacing benefits, call the WIC Helpdesk for assistance. 7. Shared Custody Between Parents and/or Guardians  The primary authorized representative is responsible to ensure that the participant receives the benefits they are issued, regardless of where the child is residing. The WIC program, or its staff, will not split the benefits for the family or intervene in the WIC status unless there is a legal custody change. 8. Temporary Loss of Income (furlough)  Benefits will be issued monthly since the situation should be temporary.

Section II: Local Agency Procedure Manual IX. Local Food Delivery B. Benefit Redemption Purpose Define the steps of an eWIC transaction at authorized vendors, including provisions vendors are required to comply with. Policy All WIC participants, authorized representatives, and authorized vendors must adhere to program requirements when redeeming WIC benefits. 1. WIC Checkout Procedures • Before the transaction begins, a WIC cardholder may tell the cashier they are paying with WIC and ask the vendor to conduct a balance inquiry using their eWIC card. Vendors are required to provide this balance if requested. The WIC approved product list (APL), and the participant’s food balance, will determine which items will be charged to the WIC account. Vendors or customers do not have the discretion to override the Point of Sale (POS) or deny the participant the item. o If a food item is not approved for that cardholder by the vendor’s point of sale, and the participant or vendor believes it is eligible, they will contact the WIC Program to investigate the product or submit the UPC for review. • The vendor ensures the eWIC card is the first form of payment accepted in the transaction. • The WIC cardholder enters their Personal Identification Number (PIN) when prompted by the vendor. • Prior to finalizing the transaction, the vendor will provide the participant an opportunity to review the transaction. o The cardholder will determine if they would like to complete the transaction. • The vendor provides the WIC participant with an itemized receipt including a remaining balance statement. 2. Store Sales, Specials and Coupons • WIC customers may participate in any store promotions offered to all customers. • The vendor will ensure the requested prices sent to WIC’s bank include any store sale or other promotion. • The WIC cardholder may receive a Buy-One-Get-One item (free item may or may not be WIC approved). The promotional product will not be deducted from the value of the WIC benefit.

• The WIC cardholdermay receive free ounces of a WIC approved product as part of a vendor promotion. The free ounces will not be deducted from the total of WIC allowed ounces. Stores may not offer incentives such as free items, prizes, or discounts solely to WIC participants. 3. Approved Substitutions • Vendors may exchange a WIC food for another WIC food of the same category (including formula) on a one-to-one basis only if the item is recalled, defective, spoiled, or outdated. 4. Non-Approved Substitutions • Rain checks, or credit slips for food purchased with WIC benefits are not allowed. All WIC foods that are redeemed by the vendor’s point of sale must be provided to the WIC cardholder at the time of the transaction. • Cardholders may not exchange WIC foods for non-WIC foods, for other WIC foods, or for cash or credit.

Section II: Local Agency Procedure Manual III. Local Management Information Services (MIS) A. Access Request Purpose SPIRIT, SPIRIT Web (SWeb), and vendor applications contains confidential participant information, to which access is limited by the DPHHS authorization of users and secure networks and equipment. Policy All access must adhere to the WIC Agency’s contract, Attachment B Equipment Agreement. 1. Access to WIC Software • The DPHHS Technology Services Division (TSD) will provide secure networks and equipment to allow access to WIC systems for hosted agencies. • Local agencies using a network or equipment not hosted by DPHHS TSD will comply with this policy by adhering to the WIC Agency’s contract, Attachment B Equipment Agreement. • All non-DPHHS users will complete the WIC System Access Request, electronically sign the TSD Non-DPHHS Employee Confidentiality Agreement, and comply with the policies listed on the agreement. WIC IT will utilize the information provided on the WIC System Access Request form to submit the TSD Non-DPHHS Employee System & File Access Request. • All local agencies will submit the WIC System Access Amendment Request to notify the State WIC Office when non-DPHHS staff require access changes to the WIC System. To grant additional access, WIC IT will submit the TSD Non-DPHHS Employee System & File Access Request. To terminate access, WIC IT will submit the TSD Access Termination Request. • All DPHHS users will complete the WIC System Access Request and follow DPHHS’ access protocol.

2. Request New User Access • Request access for new WIC staff to WIC applications using one of the tracks in the table below. State Network Users: Off State Network Users: 1. Complete the WIC System Access Request form and submit to wichelp@mt.gov. 1. Complete the WIC System Access Request form and submit to wichelp@mt.gov. 2. Complete and sign the TSD Non-DPHHS Employee Confidentiality Agreement. 2. Create an OTKA account using the instructions provided to the user from TSD. 3. Use the user ID provided to access eLearn. Complete the SWeb and Civil Rights training modules. 3. Complete and sign the TSD Non-DPHHS Employee Confidentiality Agreement. 4. Notify the State WIC Office when training is complete. Submit certificate. 4. Create account in eLearn and complete the SWeb and Civil Rights training modules. 5. When training verification and account processing are complete, the State WIC Office will contact the employee. 5. Notify the State WIC Office when training is complete. Submit certificate. 6. When training verification and account processing are complete, the State WIC Office will contact the employee. 3. Request Additional Access for Existing User • Request additional access using one of the tracks in the table below. State Network Users: Off State Network Users: 1. Complete the WIC System Access Amendment form and submit to MontanaWICProgram@mt.gov. 1. Complete the WIC System Access Amendment form and submit to MontanaWICProgram@mt.gov 2. Skip to step 4 if SWeb access was previously established. If SWeb access did not exist prior, access eLearn and complete the SWeb and Civil Rights training modules. 2. Skip to step 4 if SWeb access was previously established. If SWeb access did not exist prior, create an account in eLearn and complete the SWeb and Civil Rights training modules. 3. Notify the State WIC Office when training is complete. Submit certificate. 3. Notify the State WIC Office when training is complete. Submit certificate. 4. When training verification and/or account processing are complete, the State WIC Office will contact the employee. 4. When training verification and/or account processing are complete, the State WIC Office will contact the employee.

4. Access Termination Request • Prior to a WIC user’s last day of employment, the user’s supervisor will submit the WIC System Access Amendment form to request access termination. 5. Maintenance and Operations • The DPHHS network and equipment will be maintained by the state. Users must comply with network policies and perform maintenance actions as needed, e.g. connect equipment to the state network for weekly updates. Any state-owned equipment will be inventoried, periodically verified, and returned upon termination of use. • The non-DPHHS network or equipment will be maintained by a responsible organization or business in compliance with the hosted WIC Agency’s contract, Attachment B Equipment Agreement. Examples of this are our current contractors and their subcontractors; county governments; health care entities; and tribal governments.

Section II: Local Agency Procedure Manual X. Local Monitoring and Audits A. Local Agency Monitoring Purpose Ensure Local Agency staff understand and comply with the monitoring requirements and expectations of the biennial monitoring process. Policy Local agencies are required to adhere to local agency monitoring procedures. 1. Local Agency Responsibilities • Maintain records for each participant and program activities, which are to be made available to State or Federal Offices as requested. • Participate in the biennial monitoring process by having participants scheduled for review, preparing and/or submitting documents for review as requested in the monitoring letter, having appropriate staff available to observe and interview, and coordinating schedules with needed staff for entrance and exit interviews. • If a local agency operates a Breastfeeding Peer Counselor Program and/or an Farmer’s Market Nutrition Program (FMNP), these will be reviewed during the regular program monitoring using additional materials specific to those programs. • If appointments or activities are not available for actual observation, the monitor will interview local agency staff on their processes for validation of compliance and understanding. • Be responsible to respond to any findings by developing a Corrective Action Plan (CAP) to be sent to the State Office within 30 days of receipt of the monitoring report. • Implement approved corrective actions to comply with regulations and policies and improved program services. • The local agency is responsible for self-monitoring activities as determined by their tier level during biennial state monitoring. o Tier 1 self-monitoring will be reviewed by State staff at the agency’s next monitoring review.  The local agency will use state monitoring forms and procedures to complete this self- review. State office will provide the list of charts to be used in the self-review. o Tier 2 and 3 agencies will submit self-monitoring to the State office per the schedule set forth in the monitoring letter.  The local agency will use state monitoring forms and procedures to complete this self- review. State office will provide the list of charts to be used in the self-review. 2. Monitoring Forms • The entire monitoring process is described in the attachment Monitoring Process. This process is reviewed and updated at the end of each two-year cycle. • Forms used in the monitoring process include: o Monitoring- Breastfeeding Peer Counselor Program (BFPCP) o Monitoring- Financial Questionnaire

o Monitoring- Chart Review Areas Explained o Monitoring- Chart Review Form o Monitoring- Farmers Market Nutrition Program (FMNP) o Monitoring- On-site Observation for Clinic o Monitoring- On-site Observation for Appointments o Monitoring- Pre-Visit Worksheet o Monitoring Process • Additional resources may be located on eLearn or sent directly to the local agency during monitoring, including: o Scoring Matrix (small, medium, or large version) o Corrective Action Plan (CAP) and Verification Template o Monitoring Process Flowchart

Section II: Local Agency Procedure Manual III. Local Monitoring and Audits B. Records Management Purpose To ensure local agencies are following a standardized records retention procedure. Policy Local agencies will manage the records within their office in accordance with the procedures outlined below and their contract with the State. 1. Destruction of Records • Records with any sensitive, confidential or identifying information must be shredded, incinerated or electronically archived. • If shredding or incineration is done by someone other than WIC staff, the destruction of the records must be witnessed by WIC staff. 2. All documentation of compliance with WIC service contract, including all deliverables, expenditures and accounting/finances must be maintained and available to review upon request during the term of the contract and for 8 years following its expiration. • If an audit or any litigation is active when records would be disposed of, they must be maintained until completion of such action. • All records relating to contracted services must be made available at the request of authorized state, federal, legislative or other auditors for WIC-related reviews. • Paper files or documents do not need to be maintained when documentation is also stored electronically.

Section II: Local Agency Procedure Manual V. Local Nutrition Services and Administration (NSA) A. Local Agency Funding Purpose The State WIC Program contracts with local agencies to provide services to Montana eligible participants using Nutrition Services and Administrative (NSA) funds form USDA-FNS. Policy The Montana WIC Program will update local agency contracts annually and provide funding according to the current funding formula. Funding must be used in accordance with federal regulation and State policy. 1. Contract Process • The Montana WIC Program operates on a Federal Fiscal Year (FFY), which begins October 1st and ends September 30th annually. • Details of the contracting process may be found in Section III, V. State Nutrition Services and Administration, policy A. 2. Monthly Expenditure Report • This report is used to list expenditures paid by the local agency, using WIC funding, under the terms of the contract. • The Expenditure Report is to be completed for each month and submitted by the 28th of the following month to the State WIC Office unless an alternate date has been negotiated and written approval granted. • DPHHS has no obligation to reimburse Expenditure Reports submitted beyond the contractual submittal date or any adjustment to expenses reported more than 90 days after actual expenditure. • Expenditure reports are to be signed by both the preparer and the authorizing official (two separate people). This ensures that both parties are familiar with the financial status of the local program and improves integrity and accountability in the process. • Required Documentation: o All expenses reported to, and reimbursed by, the State WIC Office must be maintained on file for auditing, monitoring, and/or ad hoc requests by State staff, Federal staff, or other auditors. 3. Allowable Expenses Nutrition services and administration (NSA) funds are to be used for direct or indirect costs which are “necessary and reasonable” for the support and fulfillment of WIC program operations and objectives. All charges to the grant or contract must be actual and obligated within the appropriate contract period. Allowable expenses include:

• WIC personnel- includes salary and benefits for any WIC staff who are either providing clinical or administrative services or are involved in the administration of the program. o Includes staff employed by local agency or on contract. o Time may not be charged to WIC if it is also being reimbursed by another source (i.e., Medicaid billing, another grant or program). • Operating expenses such as rent, utilities, telephone, internet, office supplies and furniture, postage, and travel. • Nutrition and breastfeeding education, such as: o Holding classes demonstrating the preparation of WIC allowable foods and offering samples of what was prepared. o Items or resources for staff training and client education (e.g., model breasts, dolls, pamphlets, booklets, measuring cups, posters, etc.). • Outreach materials and activities. o Items and messaging must include WIC contact information and the USDA civil rights non-discrimination statement to count as outreach. • Travel and Training related to WIC program duties. o State Sponsored Travel or Training  If a staff member has signed up for a state-sponsored activity, but does not attend, the local agency will be responsible for reimbursing the State WIC Program. The reimbursement cannot be with WIC funding. o In State or Out of State Travel or Training  Any prior costs associated with travel or training will be expensed in the month they were incurred.  If the staff member does not attend the training, the reimbursed funds must be returned to the State WIC Program.  It is the local agency’s responsibility to keep documentation/proof of attendance for the travel or training which will be verified during the monitoring process. • Incentive items. o Must be of nominal value (< $5 per item) and promote the purpose of WIC (health and nutrition related messaging). • Memberships and dues. o Costs of professional (RD, IBCLC, etc.) certification/re-certification as part of an employee’s professional development plan, or staffing requirements, that aligns with agency policies and procedures. o Costs of relevant subscriptions or memberships to business, professional and technical periodicals, or organizations. These dues or memberships must be for the non-federal entity level, and not for individuals. An individual may be the

representative on the account or membership for the entity, however the access and benefits must be for the entity and not only the individual. 4. Examples of expenses that are not allowed (this list is not all inclusive): • Software which is provided by the State Agency (i.e. appointment scheduling/messaging/reminders, online education, shopping assistance, and language line services). • Gift Cards. • Items of nominal value that do not promote the purpose of WIC and are used for outreach, incentive, or nutrition education (personal hygiene items, facial tissues, toothbrushes, diapers, food, or beverages for staff, etc.). Items may be distributed if received or funded from another source. • Costs that are not obligated in the current fiscal and contract year.

Section II: Local Agency Procedure Manual V. Local Nutrition Services and Administration B. Time Studies Purpose Time study data is required of all WIC program staff quarterly to assure accurate federal reporting of WIC funds. Policy Staff in the Local Agencies will report all time working in the WIC program during identified months throughout the year (quarterly). Time reporting must specifically be tracked in the four following categories: Nutrition Education, Breastfeeding Promotion, Client Services and General Administration. 1. Report Months • Local agency staff, who are paid with WIC nutrition services administrative funding, will complete a time study for the following months: October, January, April, and July. 2. Report Method • Local agency staff will use the State approved recording mechanism for reporting their time. o An excel spreadsheet has been provided for local staff use to track time daily during time study months. o The time recorded for each person will be provided to the agency personnel who submits expenditure reports. A grid at the bottom of the expenditure report will be filled in with all time for all personnel reported as having worked in WIC for that month.  The amount of time claimed for reimbursement and the amount of time claimed through time study will likely be different. The time study hours will be based on days in the calendar month and the personnel expenses claimed are based on how many pay periods were drawn during the calendar month. o The report will be submitted by the 28th of the following month to the State Office Financial Specialist. o The Financial Specialist will record information for use in federal reporting.  If there is data missing, this will be requested from the local agency prior to reimbursing invoice for the month. 3. Category Descriptions • Client Services: answering phones, reminder calls, clinic set up and sanitization, WIC eligibility determination, WIC program education, weight/height, data entry, appointment(s)/book, WIC eligibility (certification/phone call/walk in) and benefit

issuance, addressing mail; communication (emails, phone calls, correspondence/letters); trouble shooting issuance problems; outreach/regional travel for client services; participant vendor counseling; WIC marketing activities; WIC survey tallying; client service education and travel; referral material development. • Nutrition Education: Individual or group education sessions and the provision of information and educational materials designed to improve health status, achieve positive change in dietary habits, and emphasize relationships between nutrition and health, all in keeping with the individual's personal, cultural, and socioeconomic preferences. • Breastfeeding Promotion: Strategies, initiatives, and services to encourage and increase the initiation and support the duration of breastfeeding among WIC participants. Breastfeeding promotion and support are considered a type of WIC nutrition education. • General Administration: Reviewing emails, policies, fiscal reports, annual budgets, month end reports, inventory and security, time studies; communication (emails, phone calls, correspondence/letters); personnel, management issues, staff supervision, staff scheduling, payroll issues, program planning, chart audits; outreach/regional travel- admin; administration education, training, travel; vendor activities, staff meetings.

Section II: Local Agency Procedure Manual II. Local Nutrition Services A. Standard Food Packages Purpose To define standard food packages for issuance of allowable foods. Policy Standard food packages are designed to meet supplemental nutrition needs for participants based on category, age, special dietary needs, and food preparation/storage needs. Standard food packages will provide the full nutritional benefit allowed (except for breastfeeding infants where minimum requested amount of formula is issued). 1. For approved food list, see attachment Approved Food List 2. Standard Montana WIC Food Packages for Infants Infant Age Amount of Breastfeeding Contract Infant Formula (Maximum amount is determined by powder reconstitution) Infant Cereal Infant Fruits and Vegetables Infant Meats

Fully None

Birth - 1 month Substantially* May be up to 4 cans

(Food Package I) Partially* 2 - 9 cans

None Up to 9 cans

Fully None

1 - 3 months Substantially* Up to 4 cans

(Food Package I) Partially* 5 - 9 cans

None Up to 9 cans

Fully None

4 - 5 months Substantially* Up to 5 cans

(Food Package I) Partially* 6 - 10 cans

None Up to 10 cans

Fully None 16 oz. 128 oz. 40oz. 6 - 12 months Substantially* Up to 4 cans 8 oz. 128 oz.

(Food Package II) Partially* 5-7 cans 8 oz. 128 oz.

None Up to 7 cans 8 oz. 128 oz.

Cow’s milk, soy beverage and goat’s milk are not issued to infants. *Infant formula for breastfed infants is calculated based on the established full nutritional benefit. However, issuance should be based on actual need rather than maximum allowable amounts.

3. Standard Montana WIC Food Packages for Children 1-5 years (Food Package IV)

Food Item Children Younger than 2 Years Children Age 2 Years and Older Milk Whole 16 quarts Non-fat, Skim or 1% 16 quarts Eggs 1 dozen 1 dozen Juice 64-oz 64-oz Cereal 36 oz. 36 oz. Whole Grain Choice 24 oz. 24 oz. Legume Choice 1 1 Fish 6 oz. 6 oz. Vegetable and Fruit Benefit $26 $26

4. Standard Montana WIC Food Packages for Women

Food Item A. Pregnant B. Substantially Breastfeeding or Pregnant with Multiples (FP V) Partially Breastfeeding or Non-Breastfeeding Post- Partum Women (<6 mo. post-delivery) (FP VI) Fully Breastfeeding, Pregnant and at Least Substantially Breastfeeding an Infant (FP VII) Fully Breastfeeding Multiples (FPVII – 1.5x) Milk Non-fat, Skim or 1% 22 qts Non-fat, Skim or 1% 16qts Non-fat, Skim or 1% 24qts Non-fat, Skim or 1% 36qts Eggs 1 dz. 1 dz. 2 dz. 3 dz. Juice 64 oz. 64 oz. 64 oz. Alternate 64oz and 128oz Cereal 36 oz. 36 oz. 36 oz. 54 oz. Whole Grain Choice 48 oz. 48 oz. 48 oz 72oz Legume Choice 2 1 2 3 Fish A: 10oz B: 15oz 10 oz. 20 oz. 30 oz. Vegetable and Fruit Benefit A: $48 B: $52 $48 $52 $78

5. Food Packages for Women Breastfeeding Multiples from the Same Pregnancy* *If more than two infants are from the same pregnancy, the mother’s food package is determined by the highest breastfeeding status of one of the infants.

How Much Breastfeeding Baby 2 Fully Breastfeeding Baby 2 Substantially Breastfeeding Baby 2 Partially Breastfeeding Baby 2 Fully Formula Fed Baby 2 Partially Breastfeeding or Fully Formula Fed 6 Months or Older Baby 1 Fully Breastfeeding

Fully Breastfeeding Multiples (1.5x Fully) Fully Breastfeeding Fully Breastfeeding Fully Breastfeeding Fully Breastfeeding Baby 1 Substantially Breastfeeding Fully Breastfeeding Fully Breastfeeding Substantially Substantially Substantially Baby 1 Partially Breastfeeding Fully Breastfeeding Substantially Partially/ Post-Partum Partially/ Post-Partum No Food Package Issued Woman Counted Baby 1 Fully Formula Fed Fully Breastfeeding Substantially Partially/ Post-Partum Post-Partum No Food Package Issued Woman Counted if Baby 2 is Partially Breastfeeding Baby 1 Partially Breastfeeding or Fully Formula Fed 6 Months or Older Fully Breastfeeding Substantially No Food Package Issued Woman Counted No Food Package Issued Woman Counted if Baby 1 is Partially Breastfeeding No Food Package Issued Woman Counted if one baby is Partially Breastfeeding

Section II: Local Agency Procedure Manual II. Local Nutrition Services B. Adjustments and Tailoring of Food Packages Purpose Tailoring a participant’s food package to meet nutritional, cultural or preference is determined by the Certified Professional Authority (CPA) after assessment and consult with the participant. Policy Tailored food packages are modified food packages designed to meet individual participant’s nutrition needs. 1. Tailored Food Packages • A modified or “tailored” food package means: o A reduction in the standard food package size  the CPA, after consideration of the participant’s individual request or needs, issues a food package with less than the full quantity of at least one food item. o Includes an item which requires CPA or RD determination based on an assessment or a prescription:  Soy beverage or milk outside the default fat level  Up to 4 cans of infant formula for a substantially breastfeeding infant in the first month  Reason for change of any infant formula  Issuance of ready-to-feed/use infant formula when powdered and/or concentrate are available  Issuance of formula to accommodate a religious preference (such as Kosher)  Replacement of some infant fruits and vegetables with a cash value benefit (CVB) o Decrease infant jarred fruit and vegetable ounces by half (64oz) for $11.00 CVB o Eliminate all infant jarred fruit and vegetables for $22 CVB o The CVB is to be provided only after an individual nutrition assessment is completed and documented. Nutrition education must be provided to the caregiver addressing developmental readiness, safe food preparation, storage techniques, and feeding practices.  Substitution of one food category item for another food category item due to personal preference, special dietary needs, homelessness, or food allergy. o Sub one legume choice in place of one dozen eggs up to the full amount of eggs provided on the food package

o Sub $3CVB for 64oz juice  Issuance of any item that is not considered “standard”, such as swapping out cheese, tofu or yogurt for milk. • Education will be provided to the participant/authorized representative concerning the recommended intake for the foods being reduced or substituted. • Tailoring of a food package will be documented in the participant’s folder. o This documentation will include whether the package was tailored based on the CPA’s assessment, based on medical documentation, and/or at the request of the participant/guardian. 2. Milk and Milk Substitutes Milk Issuance: • Fat level will be assigned in clinic based on category, age, and nutrition need. o Low-fat (1%) or nonfat (skim) milk, reduced fat (2%), and whole milk  Milk type and form will be chosen at the store for low-fat or nonfat and whole milk  Reduced fat (2%) milk requires selection of type and form in the clinic (prescribed)  Types include: 1. Cow’s Milk 2. Lactose Free Milk 3. Goat’s Milk  Forms include: 1. Fluid 2. Can/Evaporated 3. Dry/Powdered • Children under age 2 years- exceptions to standard whole milk issuance: o Fat-reduced milks (2% or 1% and skim) may be issued at the CPA’s discretion after a complete assessment for the following:  114 Overweight or at Risk of Overweight  115 High Weight for Length (but not when less than the 25th percentile weight- for-age)  Familial obesity  Trajectory of growth (after RD consult) o Assessment by the CPA of continued need will be conducted at certification and mid-certification visits.

• Children 2 years of age and older, and women- exceptions to standard low-fat/skim issuance: o Reduced fat (2%) milk may be issued after a complete assessment at the CPA’s discretion for the following assigned Nutrition Risk Factors:  101 Underweight Women  103 Underweight or at risk of Underweight – Children  131 Low Maternal Weight Gain  134 Failure-to-Thrive  335 Multifetal Gestation  338 Pregnant Woman Currently Breastfeeding  342 Gastrointestinal Disorders  347 Cancer  348 Central Nervous System Disorders  349 Genetic and Congenital Disorders  352a Infectious Diseases Acute  352b Infectious Diseases Chronic  359 Recent Major Surgery, Trauma, Burns  360 Other Medical Conditions  362 Developmental, Sensory or Motor Disabilities Interfering with the Ability to Eat o Additional reasons/conditions may be approved for issuance of 2%. Please consult State Office Nutritionist for approval. o Assessment by the CPA of continued need will be conducted at certification and mid-certification visits. Soy Beverage: • The CPA must assess and determine the approval of soy beverage for women and children. Acceptable reasons may include, but are not limited to, milk allergy, lactose intolerance, cultural practices, or the following of a vegan diet. o Documentation of reason must be made in the participant’s chart. o Education must be provided related to adequacy of dairy, or substitutes, in the diet.

Other Milk Substitutes: Milk Substitution Conversion Rates Food Item Amount Milk Rate Maximum Substitution Cheese 1 pound 3 quarts 1 pound* *participants receiving food package VII may substitute up to 2 pounds of cheese Yogurt 1 quart 1 quart 2 quarts Tofu 1 pound 1 quart Up to full amount 3. Infant Formulas • Contract Infant Formula o Montana WIC’s current cost containment contract is with Abbott Nutrition for milk and soy-based formula. o Similac Advance will be issued as the standard contract milk-based infant formula. Similac Total Comfort, and Similac Sensitive are alternate options in the milk-based formula rebate contract list. o Any of the standard milk-based options listed above are allowable with EBT at the point of sale.  Similac Soy Isomil will be issued as the standard contract soy-based infant formula • Non-contract standard infant formula (i.e., not covered in the cost containment contract) may be issued to accommodate religious preferences or by documented healthcare provider request and justification. • Formula issued in the standard food packages for infants is in the powdered form by default unless it is not manufactured in that form. o Concentrate formula may be issued at the request of the parent/guardian. o Issuance of Ready-To-Feed (RTF) formula is considered “tailoring” and requires documentation and ongoing assessment for need with each subsequent issuance. o Ready-to-Feed formula may be issued under the following circumstances:  There is an unsanitary or restricted water supply  There is poor refrigeration  The formula is available only in the ready-to-feed form  The person caring for the infant has difficulty in correctly preparing powdered or concentrate formula

 In the case of Food Package III, formulas may be issued as RTF if the physical form better accommodates the participant’s condition, such as prematurity, an immune-compromised condition, or it improves compliance in using the prescribed formula. 4. Returned Formula • A participant/authorized representative may return any purchased and unopened formula from the current benefit cycle and exchange it for a benefit with another type of formula. o If a participant is changing between formula forms, staff will use the lowest maximum allowable reconstituted amount (i.e., powdered to concentrate).  Formula replaced may not be greater than the maximum allowed, including amount recovered and/or returned.  Less formula may be issued based on need.  Staff will consider pro-ration based off days left in the current month. o If returned formula is a medical formula or WIC-eligible nutritional that the State ordered (not available for redemption at the store), document the product and amount returned in the participant chart. • Update formula in the Management Information System (MIS) SPIRIT o Verify calculation of the reconstituted value of the new type of formula so it does not exceed the maximum allowable for the participant’s breastfeeding status and/or age category. o The MIS will calculate standard formula changes. For state issued medical formulas or to verify calculations, use the following information:  subtract the amount of reconstituted formula already used (if any) from the total reconstituted amount.  divide this number by the reconstituted amount of the replacement formula to determine the number of containers/cans to issue on the reissued benefits.  round container/can amounts down to the nearest whole number.  an example: A two-month-old participant was issued 9 cans of the contract milk-based formula. The participant has used 2 cans already therefore returning 7 cans to the clinic. The participant now has a prescription for Pregestimil. The contract formula reconstitutes to 90 oz. per can, the participant has already used 180 oz. (2 x 90=180) out of the total allowable of 870 oz. Subtract 180 oz. from the total 870 oz. resulting in 690 oz. remaining. (870 – 180 = 690).

Pregestimil reconstitutes to 112 ounces. Divide 690 oz. by 112 oz. This gives you 6.12 cans of Pregestimil (690/112 = 6.12). Issue 6 cans of Pregestimil on reissued benefits. • Formula returned to the clinic may not be donated or redistributed unless approved by the State Office under extenuating circumstances o Use the Formula Tracking Log to document formula received, destroyed, or issued via direct distribution (special order formulas). o Store returned formula out of sight of participants until it can be properly disposed of as follows:  Open and pour out contents before throwing away containers. o If donation or redistribution has been allowed, document circumstances in participant record and add details to formula log. 5. Homeless Food Package • Designed to meet the needs of those who are homeless or with limited food preparation and/or storage facilities. A participant’s individual circumstances should be considered in prescribing the most appropriate food package. • Infant Feeding  Breastfeeding of infants will be encouraged.  When formula is requested, powdered formula is issued.  Ready-to-feed formula may be issued if adequate safe water is not available and documentation is made in the participant folder. • Child and Adult Food Packages  Modify standard food packages as appropriate.

Section II: Local Agency Procedure Manual II. Local Nutrition Services C.Medical Formula and WIC-Eligible Nutritionals Purpose To provide medical formula and nutritionals for participants with special medical or dietary needs. Policy Issuance of Food Package III requires appropriate medical assessment and documentation. 1. Food Package III • Medical formula includes all infant formulas which meet the requirements for an exempt infant formula under: o Sections 412(h) of the Federal Food, Drug and Cosmetic Act 21 USC 350a(h) and the regulations at 21 CFR parts 106 and 107. o These formulas are intended for use by infants with special medical or dietary needs. • WIC-eligible nutritionals include enteral products which are specifically formulated to provide nutritional support for individuals with diagnosed medical conditions when the use of conventional food is precluded, restricted or inadequate. o Not all products that meet the definition of a nutritional are eligible to be issued by WIC. • Consider Medicaid coverage of medical formula and nutritionals prior to issuance. o Consult with State Office Nutritionists as needed • Standard contract formula may be issued in Food Package III to infants with a medical prescription to eliminate infant foods for a medically fragile infant (at 6 months of age or older) due to such conditions as prematurity, feeding delays and tube feeding. o This will allow the issuance of the 4-5-month amount when the elimination of infant foods is appropriate. • To issue a medical formula/WIC-eligible nutritional, complete documentation is required. See Formula Prescription Form as the preferred method of documentation o Prescriptions not contained on this form will be accepted if they contain all the information required. o The prescription will be from a health care provider (HCP) with prescriptive authority. o Prescriptions will include:  Name of participant  Date (will be within 30 days of WIC request unless transferring from another state)  Specific name of formula or WIC-eligible nutritional

 Prescribed amount of the formula or WIC-eligible nutritional requested  Appropriate medical diagnosis/justification warranting the formula or medical nutritional use  Length of time the formula or WIC-eligible nutritional is medically necessary  Prescribed supplemental foods including the amount requested (for infants 6 months and older, children and women) or the box checked to indicate the Registered Dietitian (RD) may select the appropriate foods and duration of their issuance.  If the RD is designated to select the foods, this may include the assignment of “no foods” with documentation supporting the decision and additional formula. o A “no foods” selection will be reviewed by the RD at each visit.  The following items must be prescribed by the medical provider for WIC to issue: o Whole milk for participants 24 months and older o Infant fruits and vegetables for children and women participants o Infant cereal for children and women participants  Transferring participants from another state with an original prescription containing all the required information will be issued formula or a WIC- eligible nutritional through the end of the certification, or the prescription end date, whichever is shorter. • Approval of Food Package III o A CPA will review prescriptions for medical formulas and WIC nutritionals for compliance with WIC policies and federal regulation.  Prescriptions must be completed fully by the HCP.  The length of time requested for the prescription may be adjusted based on RD or CPA’s assessment.  Products prescribed must be appropriate for the diagnosis. Contact the State Nutritionist with questions concerning medical diagnoses or for issuance of a medical formula/WIC-eligible nutritional not listed.  Whole milk may be prescribed for children two years of age and older and women for a medical condition requiring additional calories along with a WIC- eligible nutritional/medical food.  The CPA will defer to RD for review and approval of supplemental foods when the HCP indicates this on the prescription.  Once the prescription is determined to be complete and approved, the CPA/RD must ensure this is documented in the chart.  The following conditions do not qualify for approval of Food Package III:  General intolerance to the formula, nutritional or food which does not require the use of an exempt infant formula

 Conditions or intolerances that can be effectively managed with standard substitutions in the food package  Enhancing nutrient intake or managing body weight without an underlying qualifying condition o If an exempt formula/WIC-eligible nutritional is not available through local authorized retailers, the State Office will order the formula at the request of the local agency.  The local agency CPA/RD who approved the prescription will complete a Formula Order Form and email to montanawicprogram@mt.gov.  A State Nutritionist will evaluate and order the product, which will be shipped directly to the requesting local agency/clinic.  A State Nutritionist reserves the ability to request a modification on the order, or deny, if deemed inappropriate.  Upon receipt of product, local agency staff will email montanawicprogram@mt.gov the product(s) and amount(s) received.  If the State Office has not received a confirmation of the delivery at the local agency by the expected delivery date, the State Nutritionist will follow up.  All products received must be visually inspected for any damage or defect upon delivery.  All products must be stored in a secured location, out of sight, and in accordance with all manufacture’s storage guidelines.  Formula received, issued, and destroyed must be documented on the Formula Tracking Log for inventory and integrity purposes.  Any formula distributed directly from the clinic must be prorated after the first week of the month unless documentation states a valid reason for otherwise providing a full package. 2. Standard Food Package III for Children Food Item Children < 2 Years old Children ≥2 Years old Medical Formula/WIC-eligible nutritional 910 oz. 910 oz. Milk Whole 12 quarts Non-fat Skim, or 1% 14 quarts Eggs 1 dozen 1 dozen Juice 64 oz 64 oz Cereal (cold and/or hot) 36 oz. 36 oz.

Whole Grain Choice 24 oz. 24 oz. Legume Choice 1 1 Vegetable and Fruit benefit $26 $26 Fish 6oz 6oz 3. Standard Food Package III for Women Food Item A. Pregnant B. Substantially Breastfeeding or Pregnant with Multiples Partially Breastfeeding or Non- Breastfeeding Post-Partum Women (<6 mo. post-delivery) Fully Breastfeeding, Pregnant and at least Substantially Breastfeeding an Infant Fully Breastfeeding Multiples Medical Food 910 oz. 910 oz. 910 oz. 910 oz. Milk Non-fat, Skim or 1% 16 quarts Non-fat, Skim or 1% 16 quarts Non-fat, Skim or 1% 16 quarts Non-fat, Skim or 1% 24 quarts Eggs 1 dozen 1 dozen 2 dozen 3 dozen Juice 64oz 64oz 64oz 96oz Cereal 36 oz. 36 oz. 36 oz. 54 oz. Whole Grain Choice 48 oz. 48 oz. 48 oz. 72 oz. Legume Choice 2 1 2 3 Fish A: 10oz B: 15oz 10oz 20 oz. 30 oz. Fruits & Vegetables A: $47 B: $52 $47 $52 $78

Section II: Local Agency Procedure Manual II. Local Nutrition Services D. Nutrition Education Contacts Purpose To ensure that all WIC participants are offered appropriate and up-to-date nutrition education. Policy WIC participants will be offered appropriate and up-to-date nutrition education according to standards and staff qualifications. 1. Nutrition Education Contacts • Will be delivered by one of the following methods: o Face to face (individual or group) or remotely with qualified staff. o Online/app education, and/or o Other interactive education provided by a qualified/approved source as described in this policy. • Will be conducted with the participant, parent/guardian, or their authorized representative and utilize Value Enhanced Nutrition Assessment (VENA). This participant centered method: o Identifies and addresses nutrition risks, needs, and interests of the participant in order to provide benefits that are timely and appropriate. o Incorporates the use of OARS (open ended questions, affirmation, reflective listening and summary) interviewing techniques. o Encourages interaction with the participant. • Be inclusive and respectful of participant’s culture, identity, values, and beliefs. • Consider factors outlined in care plan, when appropriate. • Be offered at no cost to the participant. • Be clearly documented in the participant’s folder by the end of the next business day. • All communications with participants must be conducted via state-approved systems . 2. Frequency of Nutrition Education Contacts During a Certification Period • Participants will be offered a minimum of four nutrition education contacts per 12- month certification period and two contacts per 6-month certification period, or approximately each quarter. o If a participant is scheduled more frequently (about every 3 months), education shall be provided with each appointment as this indicates high risk or greater intervention per the care plan.

o If the increased frequency is related to scheduling considerations, then additional education is not needed but documentation of appointment is required. 3. Individual Follow-up Education • Contact will include: o A review of the participant’s nutrition care plan. o Updated anthropometrics if indicated based on age, category, or care plan. o Follow-up on nutrition education provided at previous visit(s) including progress on resolving nutrition concerns and nutrition risk codes.  High-risk issues (as identified on the High-Risk Referrals table) should only be discussed with the appropriate staff identified. WIC staff shall only work within their scope of practice.  Low risk education may be provided by any staff who has received appropriate training. o Follow-up on and evaluation of prior referrals. o Follow-up on and evaluation of the participant’s progress toward goals.  If the goal previously set has been achieved, a new goal should be set.  If the participant declines setting a subsequent goal, this should be clearly documented. o Nutrition education based on care plan and/or current issues expressed by participant. o Includes accurate and up-to-date information based on the participant’s category, dietary history, health history, and stated interests and concerns. o The language and cultural preferences of the participants. o Documentation of the discussion in the participant folder. 4. Contacts for High-Risk Participants • Documentation of visits will be maintained in the participant’s folder, which includes: o Assessment of issues that were the basis of the referral. o Any interventions and education provided. o Plan for future appointments (RD or release to low risk). • If the appropriate staff completes the appointment where the risk was identified, the minimum requirement for this contact type will be considered met. • The next appointment will be made with the appropriate staff. o Staff may request participant attend in-person appointment if assessment determines it is necessary • When RD services are declined, high-risk topics may only be addressed with a CPA if it is within their scope of practice, otherwise, other referrals will be assessed and made to address the issue.

5. Alternate Nutrition Education for Low-Risk Participants • Group Classes: o Will be presented according to the lesson plan for the class. Lesson plans must be maintained on file for review and update as needed. o Will be presented by staff or volunteers who have been trained on the subject matter prior to teaching the class. o Document class name and record of attendance in the participant’s folder. o If group class is held through another program, such as SNAP Ed, EFNEP, or Head Start, a copy of the lesson plan shall be obtained and reviewed to ensure it meets nutrition education criteria for WIC purposes. The participant will be responsible to present documentation (such as a certificate of completion) to count as the nutrition education contact. • Web-based education and/or self-paced lessons with an interactive component. o An interactive component is defined as a two-way exchange of information and may include face-to-face, computer based through secure meeting software, or telephone. o High-risk participants who have met with the RD and are no longer considered high- risk, as their issue may be controlled or resolved, may use this form of secondary nutrition education at the discretion of the CPA/RD with documentation. o Online Education:  Provide WIC families with information on downloading the WIC Portal app or accessing the portal from a web browser. Direct them to the area in the portal to access online education.  May provide guidance on appropriate topics based on the participant’s category, nutrition risks, stated interests, concerns, and goals.  Document the topic completed in the participant folder.  Determine and document the next nutrition contact.  Follow up of goal and referral may be completed at next clinic appointment. 6. Mid-Year Assessment • A mid-certification assessment (MCA) will be scheduled for children approximately 5-7 months after certification, and at about 6 months of age for infants and their breastfeeding mothers (if applicable). This MCA will include: o Nutrition and Health Assessment  Length/height and weight measurements and bloodwork if applicable. Review results with participant/authorized representative.  Category appropriate mid-certification nutrition assessment questions.

 Response required under each question (may put “N/A” or may refer to another question if it’s already been addressed). o Nutrition Education based on the participant’s stated interests, concerns, risk codes, and/or nutrition care plan. o Review of referrals and goals made at prior appointments and provide new referrals or setting new goals if appropriate and acceptable to the participant. o Follow-up on participant’s progress of agreed upon goals, set new goal if applicable. o Plan for follow up, including:  Time (if not the standard 3 months) and type of appointment (if not standard in- person); follow-up items (hgb., wt., ht., etc. if beyond standard); and potential education for next appointment. • Mid-certification visits may be conducted using a distance method utilizing anthropometric measures and blood-work information from another qualified source within allowable timeframe for such measures. o The document needs to be completed in writing, signed, and dated by the healthcare provider or be an electronic health record. o The assessment questions and nutrition education may be completed by telephone or using a secure online platform or application. • If a participant is off schedule or misses their appointment during the timeframe specified, the mid-certification assessment will be completed at their next appointment. 7. Nutrition Forms Developed by Local Agencies • If a local agency has developed a nutrition form or pamphlet which meets a special need, it will be sent to the State WIC Office by lead local agency for approval before use. o Current, relevant, and evidenced-based content is required. Include sources where appropriate. 8. Refusal of Nutrition Education o Participants may decline nutrition education and will not be denied food benefits for this refusal, this requires documentation. o Alternative nutrition education activities will be encouraged. o Determine how many months of benefits to issue so that numerous opportunities for nutrition education contacts still exist. 9. Exit Counseling o At the final appointment for women participants (pregnancy and postpartum or breastfeeding), it is best practice to provide an exit counseling document (template available in eLearn). The counseling shall include referrals to local programs for

continuity of resource access, health tips for life stage, and local agency contact information.

Section II: Local Agency Procedure Manual II. Local Nutrition Services E. Breastfeeding Promotion and Support Purpose To ensure Federal and State requirements in the promotion and support of breastfeeding are met and to work to increase breastfeeding initiation and duration rates within the State of Montana. Policy Local agencies are to provide a breastfeeding friendly environment and breastfeeding promotion and support activities. 1. Breastfeeding Promotion and Support • Local Agency staff will encourage breastfeeding and ensure women have access to breastfeeding promotion and support activities during the prenatal and postpartum periods by: o Providing a breastfeeding-friendly WIC clinic to assure participants feel comfortable breastfeeding their infants in the clinic and asking questions about breastfeeding. o Providing educational material and access to breast pumps. o Communicating that breastfeeding is the optimal and normal way to feed an infant through visual aids, such as posters and other materials. • All materials distributed to participants will be: o Free of any items with formula product names and/or logos, except for the WIC Approved Food List materials. o Free of language which undermines the woman’s confidence in her ability to breastfeed. o An appropriate reading level for participants. o Culturally appropriate. o Accurate and up to date. • All formula, and formula related material, in the clinic will be stored out of sight of participants. • There shall be no formula related material posted around the clinic (pictures of formula, formula feeding, names of formula companies on items used, pictures of bottles, coupons etc.) • To help breastfeeding promotion, Local Agencies may want to consider: o Providing a designated and comfortable area for women to breastfeed. o Implementing breastfeeding support/education groups. o Sponsoring peer-led parenting groups

o Participating in local breastfeeding coalitions and the Statewide Breastfeeding Coalition. 2. Breastfeeding Training • Local Agency clinical staff will, at a minimum, be trained on breastfeeding promotion/support using the WIC Breastfeeding Support materials and curriculum through New Employee Training (NET), or otherwise if offered through a separate platform. • Attendance at other trainings including the Breastfeeding Learning Collaborative, Breastfeeding Coalition training(s), online classes, and other breastfeeding specific courses are highly encouraged for all staff who have direct contact with participants. • See training requirements associated with Breastfeeding Coordinator, Designated Breastfeeding Expert, Peer Counselors, and their supervisors, in respective policies.

Section II: Local Agency Procedure Manual I. Local Nutrition Services H. Breast Pump Issuance Purpose To ensure initiation or continued breastfeeding when mother and infant are separated or having difficulties with nursing. Policy Local agencies will provide a manual, single-user electric or a multi-user loaner electric breast pump to breastfeeding participants as needed and requested. 1. Local Agency Management of Breast Pump Issuance • The Breastfeeding Coordinator (BC) is responsible for overseeing the inventory and issuance of the breast pump program, and will: o Store breast pumps in a secure area that can be locked when staff are not present. o Maintain a record of inventory using the Breast Pump Log (or approved alternate form) to document:  Issuance of breast pumps  The return and cleaning of the multi-user breast pumps o Train staff that may assess and issue participants a breast pump. Only the following roles may complete assessments for issuance:  Breastfeeding Coordinator  CPA (including RDs)  Certified Lactation Counselor (CLC) on staff  International Board-Certified Lactation Consultant (IBCLC) on staff  Designated Breastfeeding Expert (DBE) and,  Senior Breastfeeding Peer Counselor o Ensure breast pumps are issued to participants at no charge. o Complete the breast pump inventory report/ordering form, as needed, located in eLearn under “Local Agency Resources” and submit it to the State WIC Office. o Assist participants reporting malfunctioning breast pumps:  Single-user electric breast pumps needing repair are reported to the manufacturer by the breastfeeding woman  Single user electric or manual breast pumps are not replaced by the local agency  Multi-user electric breast pumps that are malfunctioning may be replaced with another multi-user electric breast pump

o Make reasonable efforts to ensure the return of multi-user electric breast pumps to the local agency in a timely manner:  If the loss is from inventory on hand, report it to the state office  If it is determined that the breast pump was stolen (not returned by the participant), notify the local police, obtain a copy of the police report and scan into the participant’s folder; and  If a participant fails to return a multi-user electric breast pump to a Montana local agency without just cause (i.e., theft, fleeing domestic violence, fire, etc.), the participant is no longer eligible to receive a breast pump from the Montana WIC Program (except for extenuating circumstances). o Please refer to the Participant Fraud, Abuse and Sanctions policy for specific information 2. Eligibility for a Breast Pump • A manual pump may be issued to any breastfeeding participant who requests it. o Haakaa pumps may be issued with a CPA/RD assessment. They do not need to be tracked on pump log and no loan release form is needed. Education on how to use the pump and documentation of issuance is required. o Other manual pumps shall be documented on log and include a release that is signed and scanned into the participant’s chart. • A multi-user breast pump may be issued for loan to a breastfeeding participant who needs to establish or maintain a milk supply in the following circumstances: o Woman who will be separated from their infants due to work, hospitalization, or custody issues o Woman who is sick and unable to breastfeed or prescribed a contraindicated medication for a short-term period o Woman who may temporarily not be directly breastfeeding for medical reasons. o Woman with an infant with physical or neurological impairment such as weak suck, uncoordinated suck/swallow pattern, inability to suck, or inability to latch on to the breast o Woman with low milk supply o Woman with multiple breastfeeding infants o Woman who wants to re-lactate, and o Woman inducing lactation (i.e., for adoptive child). • Single user* electric breast pumps are available for breastfeeding participants who need help maintaining their milk supply in the following circumstances: o Woman who has been breastfeeding at least one month and has a long-term goal of breastfeeding duration

o Woman who is regularly separated from her infant (i.e., return to work or school, infant/woman hospitalization or sharing custody of an infant) o Woman with multiple breastfeeding infants *Women who received a single user pump from Medicaid or Private Insurance shall not be issued a single-user pump from WIC unless it has been determined and documented that their pump is ineffective, defective, or woman has other extenuating circumstance. 3. Procedures for Pump Issuance • Breast pumps may not be issued to a pregnant woman unless they are breastfeeding a WIC participant infant and approval has been obtained from the State Office. A postpartum certification must be scheduled and reasons for issuance must be documented. • Confirm the participant does not have an effective Medicaid or private insurance issued single-user breast pump. If they do have a pump, reason for issuance shall be documented (i.e., different kind of pump needed). • Complete an assessment of the breastfeeding dyad (within scope of practice), identifying and addressing any issues or concerns. Referral to a lactation expert must be made when scope has been reached. • Determine eligibility for a type of breast pump based on assessment of the situation. • Discuss pumping techniques and safe handling of expressed breast milk including: o Plan for pumping (frequency, effective techniques) o Use the manufacturer’s instructions to demonstrate how to assemble, use and clean the breast pump o Sanitary practices (hand washing, cleaning pump and accessories, etc.) o Storage times and temperatures (freezing and refrigeration), and proper thawing and warming techniques (provide written instructions) • Observe the participant demonstrating assembly of the breast pump. • Complete the Breastfeeding-Single User Breast Pump Release Form or the Breastfeeding-Multi-User Electric Breast Pump Loan/Release Form. o Scan it into the participant folder. o If using the Breastfeeding- Multi-user Electric Breast Pump Loan/Release Form give a copy to the participant. • For multi-user pumps only- document under the Item Issuance tab in MIS that the pump has been issued by entering the serial number and having the participant sign. • Provide a phone number to call for help or support.

• Follow-up with participant will be completed and documented within three business days after issuance, and then weekly or monthly thereafter dependent on the issue requiring a pump and the projected length of loan (for multi-user pumps only). o An individualized follow-up plan for each participant must be documented and followed. • Complete the Breast Pump Log and document issuance of multi-user pumps in MIS. • Collaboration with Outside Agencies o After WIC staff assessment and/or certification, an outside agency may issue a pump on behalf of the WIC staff if:  A release of information is on file to allow for communication between the issuing entity and WIC.  All other policies regarding pump issuance must be followed. 4. Return of Multi-user Breast Pumps • Multi-user breast pumps will be returned to the Local Agency immediately when the pump is no longer needed.  If a pump is issued by an agency that is not the participant’s primary agency, please document who will be following-up with the participant and which clinic the pump is expected to be returned to.  The pump should be listed on both agencies’ pump logs with current status (i.e., pump #1234 transferred to clinic XYZ with participant move ID#123456). • A single user electric breast pump may be issued to a participant returning a multi-user breast pump if eligibility is met. • Return and cleaning of multi-user breast pump will be documented on the Breast Pump Log. Staff will check the pump case for any damage, plug the pump in to ensure it is in good working order, and clean the pump motor casing with a mild bleach solution (1- part bleach to 10 parts water) or medical-grade cleaner such as cavi-wipes. The cleaner should be virucidal, bactericidal, tuberculocidal, AND fungicidal. • Return of a multi-user pump must be documented in MIS under the Item Issuance tab where the pump was initially issued. 5. Broken Pumps • Any multi-user pump determined to be non-functioning should be reported to the state Breastfeeding Coordinator. o Include the following in an email:  pump type (symphony or lactina)  pump serial number  reason for pump not working (i.e., no suction, missing pieces, no cord, etc.)

Section II: Local Agency Procedure Manual II. Local Nutrition Services G. Breastfeeding Peer Counselor Program Purpose: Provide peer-to-peer breastfeeding counseling to promote and support initiation and duration of breastfeeding among WIC participants. Policy: The Montana WIC Program will select site(s) for local Breastfeeding Peer Counselor Programs which will receive identified Breastfeeding Peer Counselor funding. Other local WIC programs may fund Breastfeeding Peer Counselor Programs from their regular WIC administrative funds or other grant funds. All local Breastfeeding Peer Counselor Programs, regardless of the funding source, will comply with the Montana Breastfeeding Peer Counselor policies and the Food and Nutrition Services (FNS) model. 1. Local Breastfeeding Peer Counselor Programs (BPCP) • Initial applicants for the Breastfeeding Peer Counselor Program will complete an application packet* found as an attachment in the state plan. The application will address the following: o Identify Breastfeeding Peer Counselor Program Supervisor o Recruitment and training plan for the Breastfeeding Peer Counselor o Method of referral to the Peer Counselor from clinic staff o Contact methods o Plan for referral to breastfeeding expert when needed, and o Plan for outreach with community resources *Programs will submit updates if changes to the proposal are made during the year. • Will submit the following required reports: o Monthly expenditure reports for reimbursement which requires the detailed attachment on BPCP funds o Complete the annual report form for the period of May 1 to April 30 (or part of year during initial year) due by May 15th • Will be responsible for recruiting, hiring, and training Breastfeeding Peer Counselors • Will retain records per contract criteria • Will have technical assistance provided by the State Breastfeeding Coordinator, and • Will submit local agency developed policies to the State Breastfeeding Coordinator prior to implementation.

2. Breastfeeding Peer Counselor Program Staffing • State Breastfeeding Coordinator responsibilities: o Oversight for the operation of all Breastfeeding Peer Counselor Programs o Coordinate state level activities including program selection, contracts, training, funding, monitoring, and evaluation. • Local Breastfeeding Peer Counseling Supervisors/WIC Designated Breastfeeding Expert (DBE)*required: o May be a WIC staff member, contractor, or other appropriate staff member in the agency o Have at least 1 year of experience in counseling women about breastfeeding o Preferably holds additional certification in lactation management, such as the IBCLC, CLC, or other certification in lactation management o Participate in state-provided training, and o Provide training and oversight for local peer counselors and overall local BFPC Program using the WIC Breastfeeding Support model. • Breastfeeding Peer Counselor will be: o Recruited from the target population o Available to consult with participants outside clinic hours and outside the clinic environment o Has previous breastfeeding experience of at least 6 months o Able to meet the following criteria:  Enthusiastic for breastfeeding  Has effective communication skills  Ideally, is a current or previous WIC participant or would have qualified for WIC, and is similar in race or ethnicity, age and language spoken of target population. o Is not a CPA, management, or other professional staff in WIC agency. o A BPC may not have a health professional credential (RD, RN, LPN, etc.) or IBCLC certification:  Those presently holding BPC positions prior to October 1, 2017, are grandfathered in their positions, and are not required to meet these criteria.  If a health professional degree or credential, or IBCLC certification is earned during the tenure of the BPC, the BPC must still stay within their scope of practice.  Ideally, staff who advance their education, credentials and skillset would move on to a position where they could utilize them. If this opportunity is available it is encouraged, and the agency can re-hire another staff who meets the above criteria.

o Will have regular and systematic contacts with the Local Breastfeeding Peer Counselor Supervisor to conduct a review of contact logs and activities. o Will receive referrals from other staff. o Will make appropriate referrals for issues outside of their scope of practice as defined by the USDA. o Will sign scope of practice agreement upon hire. o May make contacts remotely from home and/or the clinic using a secure method. o May conduct home and hospital visits (will be specified in the job description). o May conduct breastfeeding classes within their scope of practice. o Will make the following required contacts:  Once per trimester during pregnancy (once certified and referred).  Within one week of expected due date.  Every 2-3 days in the first critical 7-10 days postpartum; daily if the woman reports problems with breastfeeding.  Weekly throughout the rest of the first month of the infant’s life; and  Monthly after first month of infant’s life.  If participant requests a different contact frequency or declines, document this in the participant folder. o All activities with the participant will be documented in the participant’s folder within 5 business days by the Peer Counselor. Documentation will include:  Typed managed note under “breastfeeding”, and  Breastfeeding “contact” in MIS within the mother’s chart only,  Incomplete contacts will include a brief note of the attempt and a breastfeeding “contact” in SPIRIT with “attempted contact” selected in the discussion topic section. 3. Training for Breastfeeding Peer Counselor Program • The State Breastfeeding Coordinator will work with the Local Breastfeeding Peer Counselor Supervisor during the initial contract to address training needs and resources. • Local Breastfeeding Peer Counselor Supervisors will be trained in the WIC Breastfeeding Support training curriculum. • Local Breastfeeding Peer Counselor Supervisor will train peer counselors utilizing the most up-to-date WIC Breastfeeding Support training. • Local Breastfeeding Peer Counselor Supervisor and Peer Counselors will be required to maintain continuing education credits according to WIC policy. 4. Establishment of Community Partnerships Local programs will promote breastfeeding peer counselor services throughout other organizations and communities and create referral networks. These may include

breastfeeding coalitions, local businesses, Community organizations, cooperative extension programs, local lactation consultants/counselors, La Leche League and other local support groups, Home Visiting programs, healthcare providers, and delivery hospitals.

Section II: Local Agency Procedure Manual II. Local Nutrition Services K. Nutrition Education and Breastfeeding Education Plans Purpose To assure appropriate nutrition and breastfeeding education and activities, are planned to address the nutritional needs and interests of WIC participants. Policy Each local agency will create, follow, and have on file a Nutrition and Breastfeeding Services Plan. 1. Nutrition and Breastfeeding Education Plan • Each local agency will have a nutrition and breastfeeding services plan on file with the State Office. The plan will be aligned with the State Agency Nutrition Services Plan and include: o An assessment/progress update of the prior year goals, objectives, activities and/or metrics. o Selection of at least three objectives. Each objective will have an action plan associated with it and identified resources and timelines to achieve. o Each plan will be for 2 years, with a brief mid-point assessment due. • The Nutrition and Breastfeeding Services Plan will be led by the Local Agency Nutrition Coordinator (NC). o The NC will monitor the plan and ensure progress is made and documented. o The NC will work with local agency staff to plan activities and/or interventions to work toward meeting goal(s). • Local plans must be reviewed and approved by the State Office. Due dates and instructions will be provided. o If plans are not submitted, updated, and approved, this may result in a monitoring finding for the period of non-compliance.

Section II: Local Agency Procedure Manual IV. Local Organization and Management A. Local Agency Staffing Purpose To ensure that each local agency employs or contracts with adequate staff to ensure participants receive high-quality nutrition services. Policy Each Local Agency is required to have qualified staff to fulfill each required role. 1. Staffing • Qualified staff must be employed or on contract to provide WIC services in accordance with the federal regulations, State Plan policy, and agency contracts. o Contract budget, participation, and local agency needs should be considered when determining staffing levels for WIC services. 2. Local Agency Staff Training • Completion of all required and necessary training for a position will be overseen by the direct supervisor over the staff. Any training related to Nutrition and Breastfeeding must also be reviewed with the Nutrition Coordinator (this may or may not be a different person than the supervisor). The role of the Nutrition Coordinator is to ensure the staff have the competencies necessary to provide nutrition and breastfeeding education within the role’s scope and using the most up to date and relevant information. o The Nutrition Coordinator is a required role in WIC and is further described below. • All new staff must complete the following training, at a minimum: o Civil Rights (prior to system access granted and then annually) o All training described for role on the Staff Training Form (in eLearn)  Form and supporting documents must be submitted to the State Nutrition Coordinator within 60 days of hire. If there is reason to exempt a training, this will be documented on the form. Exemptions will only be made when the staff has prior training or experience in the area adequate to meet the requirements of the position. o New Employee Training within 12 months of hire. This training is offered about every 6 months and is managed by the State Nutrition Coordinator. This training is designed for any staff who deliver direct services in clinic.

• Continuing education is required for all staff who provide direct clinic services to participants which includes some component of nutrition and/or breastfeeding education. o Staff employed >20 hours per week are required to complete 12 credit hours per 12 months, staff employed <20 hours per week are required to complete 6 credit hours per 12 months. o Continuing Education Credits (CECs) must be approved (pre or post event) by using the Continuing Education Credit Approval Form, which is submitted to the Nutrition Coordinator at the State Office. 3. Local WIC Clinic Roles: • WIC Director (required) o A WIC Director is responsible for overseeing the administrative aspects of the WIC Program. Typical responsibilities include fiscal management, program planning, staff supervision, serving as a contract liaison and ensuring breastfeeding promotion and support activities within the local program. • Competent Professional Authority (CPA) (Required) o The role of the CPA in WIC is to:  Assess and document nutrition risk  Prescribe and issue food packages  Develop care plans to meet the participant needs and stated goals  Provide participant centered, up to date and culturally relevant nutrition and breastfeeding education and support. Refer high-risk individuals to the agency Registered Dietitian Nutritionist (RDN) or other specified professional on the High-Risk Referrals attachment and make other referrals as required or appropriate. o At least one of the following credentials/qualifications are required to fulfill the role of the CPA:  Registered Dietitian (RD)/Registered Dietitian Nutritionist (RDN)  Each local agency must have at least one RD/RDN on staff or contract to provide high-risk nutrition services to participants, provide consult on Nutrition & Breastfeeding Education plans, coordinate nutrition and breastfeeding related training for staff to ensure scope of practice and evidence-based services are adhered to, and review and approve prescriptions under Food Package III including food packages (when indicated by healthcare provider).  RDNs must be state-licensed and maintain their licensure and credential in good standing throughout their employment in WIC.

 Refer to attachment WIC Remote Registered Dietitian Scope of Services for additional detail on the role of a contracted/remote RD/RDN.  Nutritionist with a bachelor’s or master’s degree from any college/university which is accredited/approved by the Accreditation Council for Education in Nutrition and Dietetics (ACEND)  Dietetic Technician, Registered (DTR)  Registered Nurse (RN)- this does not include Licensed Practical Nurses (LPNs)  Physician (Medical Doctor or Doctor of Osteopathic medicine)  Physician’s Assistant (PA) o Other professional with a health and/or science related degree with adequate coursework (within the last 10 years if not actively working in the field of health and/or nutrition) which will include, at a minimum:  Basic Nutrition  Nutrition in the Life Cycle  Completed series of Anatomy/Physiology  One additional course in nutrition such as Community Nutrition, Weight Management, Culinary Nutrition, Nutrition in Chronic Disease, Motivational Interviewing, or equivalent counseling class. o Prior to hiring the local agency must submit the Request for Hire form to the State Nutrition Coordinator for approval. Documentation to support the credential, training, education, or experience will be submitted according to the role as identified on the form. The Nutrition Coordinator, or their designee, may consider other candidates on a case-by-case basis. • Nutrition Coordinator (NC) (required) o This role must be filled by a Registered Dietitian Nutritionist (RDN), and is responsible for:  Ensuring the WIC clinic is delivering nutrition services, including education and support, using up to date, relevant and participant-centered methods, and information. This role will also provide oversight and coordination around the development of the annual Nutrition & Breastfeeding Plans as well as ongoing monitoring of plan progress.  Required training for staff will be enforced by the staff’s direct supervisor, however, the NC will coordinate on this effort to ensure the training needs related to quality services and alignment with the annual Nutrition & Breastfeeding plans are met

• Breastfeeding Coordinator (BC) (required) o The BC will:  Promote and support breastfeeding both within the clinic and through community engagement and partnerships. This person must be familiar with the WIC program and policies  Manage breast pump inventory and issuance  Be available for consult on breastfeeding issues outside of the scope of clinic or peer counseling staff  Ensure clinic staff are providing relevant, up to date and participant centered services (within scope) related to breastfeeding o The BC will meet qualifications as a CPA or will be an aide with an additional lactation credential (CLC or equivalent). o BC without additional lactation credentials will enroll in a certified lactation counselor (CLC, or equivalent) course within one year of assuming the role o Additional preferred qualifications for the BC include:  One year of experience in counseling women about how to breastfeed successfully, and  Hold credentials of International Board-Certified Lactation Consultant (IBCLC)* as granted by the International Board of Lactation Consultant Examiners o A Designated Breastfeeding Expert (DBE) is required for all breastfeeding peer counselor programs. The DBE may or may not be the agency’s BC. o See the breastfeeding peer counselor program policy for additional position details. 4. Local Agency Retail Coordinator (LARC) (required) • Each local agency will select a staff member to act as a LARC. This position is the primary local contact for WIC Authorized Retailers. The WIC State Office may delegate vendor monitoring, pre-authorization visits, compliance buys, and vendor training to LARCs. Training of the LARC will be provided by the State office vendor team. 7. Nutrition Aide (optional) • A Nutrition Aide, Nutrition Assistant or similar job title is responsible for a variety of duties dependent upon the local agency’s needs and staff competencies. o Typical job duties include, but are not limited to:  Gathering demographic information  Screening and determining categorical, residential, and financial eligibility  Gathering height, weight, and biochemical information  Describing food delivery system and food list  Issuing benefits and explaining use

 Scheduling appointments  Making referrals to community services  Providing excellent customer service to participants  Performing general clerical duties  Providing program outreach o Per the Clinical Laboratory Improvement Act regulations, staff performing biochemical tests must possess a high-school diploma or the equivalent. o After completing appropriate training, as documented by the local agency Nutrition Coordinator, Nutrition Aides may collect participant health information and provide low-risk, basic nutrition, and breastfeeding education.

Section II: Local Agency Procedure Manual IV. Local Organization and Management B. WIC Employee Integrity Purpose To provide guidance to local agencies on separation of duties and reducing the risk of fraud where there is a conflict of interest. Policy Local agencies must ensure integrity in certification and other clinic processes. 1. Separation of Duties • Each WIC clinic will have staffing, and clinic structure/flow, to enable a separation of duties including a division between income eligibility determination and nutrition risk code assignment during certifications. • When adequate separation of duties is not possible, selected certification records will be audited by the State Office within two weeks, per FNS WIC Policy Memorandum #2016-5 Separation of Duties. Documentation will be maintained by the State Office. • During Waiver Status: o When separation of duties is not possible, due to remote appointments, 20% of all certification records, where the income and nutrition risk contacts are completed by the same staff, will be audited by an automatic process within two weeks and documentation will be maintained. o Data will be pulled and ranked on a priority system, including certification duration, risk codes, card signatures, eligibility documentation, signature for participant rights and responsibilities, and income. o State Office Public Health Nutritionist will verify the charts that meet the high priority level threshold. 2. WIC Employee Integrity • Local agency employees may not act as authorized representatives, alternate representatives, or proxies for participants (unless it is their own personal family or household unit that is participating). o A WIC employee or family member of a WIC employee may participate in the program. o The entire WIC certification must be completed by another WIC employee that does not have a conflict of interest or close relationship to the applicant/participant. o The local agency may contact the State Office to assist in completing the certification where a conflict of interest cannot be resolved with alternate staff locally.

 The appointment shall be scheduled ahead of time with the State Office staff. 3. Business Conflict of Interest If any potential or real conflict of interest between local agency staff, either state or local, and an identified business’ personnel, the local agency shall: • Notify the State WIC Office of any potential conflicts of interest which may include, but are not limited to: o Employment of a staff member or spouse, son, daughter, parent or sibling of a local or state WIC agency staff member by the business within the local agency or State WIC Office jurisdiction. o Receiving a fee or gift from a business in exchange for providing WIC information, or WIC staff action that would materially benefit the business, or for preferentially promoting the business. o Receiving, either directly or through a relative, a substantial gift of financial assistance from a local business. o Entering into a business transaction with a local business or a staff member acquiring a pecuniary interest in a business. • The State WIC office reserves the right to prohibit activities which compromise the integrity of the program.

Section II: Local Agency Procedure Manual IV. Local Organization and Management C. Local Agency Selection Purpose This policy provides general guidance for applying to operate a WIC clinic at the local level, as well as site selection determinants. Policy It is the policy of the Montana WIC Program to accept applications for providing WIC services in a designated service area and via satellite clinics ongoing. Applications will be considered based on the information provided and placement in the Affirmative Action Plan. 1. Structure of Contract Awards for WIC Local Agencies • It is the goal of the Montana WIC program to service the entire geographic area of the state. All counties and reservations shall be covered for service delivery through contracts with local entities. • Any counties or reservations that have a master contract with the State of Montana DPHHS may be awarded a task order to provide WIC services locally, covering an agreed upon region (may include several counties) where this is in the best interest of the Montana WIC program. o The lead agency requesting and accepting the task order must be fully able to provide all WIC services and provide adequate oversight of any satellite or outlying clinics in their region. Sub-contracts for service delivery require approval by the State WIC Director. • WIC contracts may also be awarded based on competitive bidding process, or Request for Proposal (RFP). • Determination of service site delivery (clinic locations and schedules) will be made by the lead local agency holding the contract or task order for the region. Consideration shall be given to: o Placement of the location in the Affirmative Action Plan. o Potentially eligible population. o Interest or demand by the residents; and/or, o Feasibility and cost effectiveness. • Opening additional sites within a region requires an application to be submitted to the State for review and approval. • Closing existing sites, or significantly changing the location of an existing site, requires completion of a Civil Rights Impact Analysis which is covered in policy A. Civil Rights/Non-Discrimination and Complaints within Section. II Local, XI. Civil Rights.

2. Application Process • The process for applying to operate a WIC clinic, including additional locations within an existing agency region, or conversion from a satellite site to a local agency region, is: o Submit the attachment, Application for a Local Program to the State WIC Director, the State Director will respond:  Within 15 calendar days after receipt of an incomplete application to provide written notification to the applicant agency detailing the additional information required.  Within 30 calendar days after receipt of a complete application, the applicant will be notified in writing of approval or disapproval of application. o Within 90 days notification of approval, the State WIC Office will complete the following activities:  The new clinic(s) IT department will work with DPPHS to ensure all WIC software is assessable, installed, and maintained on applicable machines. o The new clinic(s) operating on local network’s will be provided funding in the contract along with contract language outlining the requirements for WIC.  Notify the bank of additions to the system  Update Local Agency Directory (LAD), phone lists and other contact or communication forms  Any other activities as required to assure that additional sites are functional • Additional clinic sites may not open until final written approval is received from the state WIC office. • Additional funding will be considered on a case-by-case basis and is dependent on funding availability as well as how the clinic addition alters the funding formula. • Additional funding for equipment to furnish a new site will be evaluated on a case-by- case basis. • When an application is disapproved, the applicant agency will be given written notification of its right to appeal, and of the reasons for disapproval. 3. Review Criteria • The review criteria for selection of local programs to administer the WIC program will include, but is not limited to, the following factors: o The applicant’s position in the attachment Affirmative Action Table o Adherence to 7 CFR 246.5:  Priority A: A public or private non-profit health agency that provides ongoing routine pediatric and obstetric care and administrative services.

 Priority B: A public or private non-profit health or human service agency that will enter into a written agreement with another agency for either ongoing routine pediatric and obstetric care or administrative services.  Priority C: A public or private non-profit health agency that will enter into a written agreement with private physicians, licensed by the State, in order to provide ongoing routine pediatric and obstetric care to a specific category of participants (women, infants or children).  Priority D: A private or non-profit human service agency that will enter into a written agreement with private physicians, licensed by the State, to provide ongoing routine pediatric and obstetric care.  Priority E: A public or private non-profit health or human service agency that will provide ongoing routine pediatric and obstetric care through referral to a health provider. • The applicant’s plan for providing linkages with appropriate health care providers. • Supporting documentation of the projected caseload must accompany the application. Historical data from prior contractors may be used. • The applicant’s projected ability to meet WIC Program regulations and State policies and procedures. • The qualifications of the staff, the applicant’s history of performance in other programs, and in administering similar public health services. • The applicant’s ability to make the WIC program accessible to participants. • The applicant’s projected cost of operations. • Participant access to services (i.e., distance to another WIC clinic which can meet the needs of the community).

Section II: Local Agency Procedure Manual IV. Local Organization and Management D. Security and Disaster Recovery Plans Purpose To have a written plan of guidance to recover from natural and/or man-made disasters which disrupt or interfere with the regular delivery of program services. Policy All WIC local agencies will have a written plan for system security, continuity of operations and disaster recovery that will be updated as needed. 1. Emergency Preparedness • Each local agency shall have a plan in place to address potential disruption in services due to a disaster, including a pandemic situation. • Local agencies will notify the State WIC Office if they have a situation that affects their ability to deliver services. o The local agency has the primary responsibility of managing the situation, however, the State Office will provide guidance and resources as able and available. 2. Plan Content • The local agency is required to have a written plan for system security and disaster recovery. Each plan will address the following topics: o Designation of an agency Security Manager. o Emergency preparedness.  Contingency plans to meet critical processing needs in the event of short or long­ term interruption of service. o Physical security of computer resources. o Protection of equipment from theft and unauthorized use, Incorporation by reference, “Special Supplemental Nutrition Program for Women, Infants and Children (WIC) Guide to Coordinating WIC Services During Disaster”. 3. WIC Service Delivery During Disaster, Pandemic, or Food Supply Chain Disruptions • During an emergency USDA may be granted waiver authority to allow State and Local agencies to continue providing services. • Flexibilities currently authorized in regulation may be exercised at the discretion of the State Agency to ensure WIC participants are provided services. Some examples include the following, however additional flexibilities may be identified and implemented as needed: o Minimum stocking requirements may be waived at State Agency discretion.

o Remote service, including follow up education and benefit issuance, may be done on any currently certified participant. o Bloodwork may be delayed up to 90 days for any participant currently certified if remote service is being used and healthcare provider referral data is not available. o Certification periods may be extended for up to 30 days with State Office support and guidance. o EBT card replacements may be mailed by certified mail (signed receipt) if in-person pick up is not possible.  New EBT cards must be provided in person. 4. Waivers • Waiver authority for any regulatory or policy provision for WIC may be provided by congressional order. When waiver authority is provided to USDA, States may request individual waivers that are relevant and responsive to the current situation. • When waivers are approved, the State Office will provide process documentation to all local clinics, retailers and interested parties to describe implementation of any said waiver.

Section II: Local Agency Procedure Manual IV. Local Organization and Management E. Local Agency Policies Purpose Local agencies are responsible to provide WIC services as specified in their contract with DPHHS/WIC, federal and state regulation, and the State Plan policies and procedures. Policy WIC program policies developed by a local agency for local WIC operations must be approved in advance by the State WIC Office. 1. Local Agency Program Policies • Local agency program policy format is of the local agencies choosing and must be dated and signed by the local WIC program director, or other designated management staff, and contain the current federal non-discrimination statement. • Local agency policies that have any potential impact on WIC operations, WIC participants, or vendors, must receive prior approval from the State WIC Office. • Policies must not conflict with other State Plan policies, local agency contract, or federal regulations. 2. Posting • It is strongly recommended that local policies be posted in a highly visible location in the WIC office, particularly if the policy affects participants. o Example: Policy statements about no-shows or appointments.

Section II: Local Organization and Management IV. Local Organization and Management F. Inventory Management Purpose To provide guidance on ordering and managing an inventory of materials from the State Office. Policy Local agencies will order materials from the state office and are required to follow inventory management procedures. 1. Local Agencies may place orders on an ongoing basis throughout the year, to ensure sufficient participant and/or household needs are met. • State Office will evaluate local agency order quantities and adjust accordingly. • The lead clinic will be responsible for placing all orders with the state office, and the State Office will ship to any clinics identified in the order. 2. Benefit Card Stock • The lead agency will contact the state office to place an order for card stock as needed. • The State Office will ship stock to the clinic identified in the order via certified mail. • Benefit Card Stock Security and Inventory Control o Benefit card stock will be always stored in a locked location. o Local agency is required to maintain an inventory log of eWIC cards received, destroyed, and mailed to participants o Documentation is to be made on attachment eWIC Card Inventory Log. This must be available for review at the State’s request. o If a card is damaged and discarded prior to issuance, this needs to be logged including the card number(s). o Cards issued by the clinic (except when mailing), or replaced by the eWIC Processor, do not need to be logged on the inventory form. 3. Breast Pumps • The local agency Breastfeeding Coordinator (BC) is responsible for overseeing the ordering, inventory, issuance and reconciliation of breast pumps, and will: o Order breast pumps by completing the WIC Order Form, located in eLearn under “Local Agency Resources” and submit it to the State WIC Breastfeeding Coordinator. o Breast pumps will be stored in a secure area that can be locked when staff is not present. o Maintain a record of inventory, issuance, and return of breast pumps using the Breastfeeding- Breast Pump Log (or approved alternate form that has the same information contained in it). o Log pump issuance in participants’ chart in the MIS as directed by state office.

4. Other Materials Supplied by the State Office • The State Office will provide materials that are either required or fundamental to use in the program. • The Order Form for these materials is located on the State of Montana eLearn site.

Section II: Local Agency Procedure Manual I. Local Vendor and Farmer Management A. Retailer Education/Training Purpose Retailer training ensures retailers meet all program requirements. Policy The Montana WIC Program provides annual training to ensure retailers understand and comply with program requirements. 1. Description of Retailer Education or Training • Retailer education and training is designed to help reduce errors, prevent abuse, and improve program services. Education/training may be conducted by the Local Agency Retail Coordinator (LARC) or State Agency staff. • The WIC Program is required to provide education and training for the following reasons: o Retailer is newly authorized. o Annually, which may be interactive, and provided as either an on-site training or, a training video, or a training newsletter. o Required education/training as directed by the Montana WIC Program as part of a Corrective Action Plan (CAP). o Non-compliance with the Montana DPHHS/WIC Retailer Agreement. • The WIC Program may choose to provide education/training for the following reasons: o Retailer requests education/training. o Retailer has violated program regulations. • Interactive training is an opportunity for questions and answers and must be provided at least once every three years. The LARC will conduct interactive training as part of retailer monitoring visits. Failure to attend interactive training is a program violation. 2. Training Content • Both annual and interactive training will include all the following topics: o Purpose of the WIC Program. o Supplemental foods authorized by the Montana WIC Program. o Minimum stocking requirements. o Procedures for eWIC transactions. o Montana WIC Program retailer sanction system.

o Method by which retailers may submit a program complaint. o The claims procedure. o Requirement that infant formula must be purchased from an approved distributor. o The use of incentive items. o Any changes since the last education/training effecting retailers. 3. Test Cards • Some situations may require an active eWIC card to test vendor systems. • Montana WIC does not provide test cards to all vendors and makes the determination to provide a test card on a case-by-case basis. Test eWIC cards must be requested from State WIC vendor staff and are loaded with live benefits through the State’s MIS. • Point-of-Sale operators and other WIC vendor stakeholders may conduct remote testing in the EBT processor’s test environment to troubleshoot issues or configure setup. Testing that occurs on site, in the store will occur in the live production environment. • State WIC staff will provide directions on the testing procedures on a case-by-case basis, including the requirement to void the transaction prior to finalization. Testing that requires finalizing the transaction requires donation of the purchased food benefits according to program procedure.

Section II: Local Agency Procedure Manual I. Local Vendor and Farmer Management B. Retailer Monitoring Visits Purpose Retailer monitoring visits allow the WIC Program to ensure authorized retailers follow all program requirements. These visits help the WIC Program detect possible fraud and/or abuse, discuss with the retailer staff any problems/solutions, and the opportunity to provide interactive training. Policy A minimum of 5 percent of retailers will be monitored every fiscal year and authorized retailers will receive a minimum of one monitoring visit per contract period. 1. Routine Monitoring Visits • Retailers may be selected for monitoring every other year. Monitoring visits are performed in accordance with federal and state regulations. • Monitoring visits will be conducted by local agency and/or State WIC staff. • At each monitoring visit, staff will: o Verify that the “We Accept WIC Benefits” signs are posted. o Verify that food prices are clearly posted, either on the shelves, or on the individual food items. o Examine minimum stocking requirements, including:  If the retailer has a stocking exemption, verify that an exemption sign is clearly posted where WIC participants can view it.  If a store does not meet the minimum stocking requirements, a follow up visit must be scheduled and completed within 30 days of the initial store visit to ensure the items have been stocked. Retail staff may provide a photograph of the items in-stock in lieu of a subsequent store visit. o Complete the mandatory interactive training and ensure the store managers have initialed each topic of interactive training. o Discuss any problems the retailer has experienced and provide assistance on site. o Determine if fraud or abuse is suspected. o Record the printed name and signature of the retailer and LARC present at the monitoring visit.

Section III: State Agency Procedure Manual VII. State Caseload Management A. State Office Outreach Purpose The State WIC Office is responsible for coordination of statewide outreach activities, including coordination and support of local agency outreach efforts. Policy The Montana WIC Program will do outreach to potentially eligible Montana residents annually, and ensure local agencies are effectively doing outreach in their respective regions. 1. State WIC Office will: • The State WIC Office will participate in an annual and/or ongoing outreach activities or campaigns. • The State WIC Office will use available opportunities to educate health professionals about WIC services and benefits. • The State WIC Office will provide agencies, organizations, and offices in their network with materials describing WIC services. 2. WIC program website includes: • Names and addresses of the local agencies • Names and addresses of WIC retailers • Eligibility criteria and information on program benefits • The civil rights non-discrimination statement • The toll-free phone number for the State WIC Office 3. Promotion of Services • Prepare and distribute outreach materials to local programs for use in recruiting new WIC participants, and in providing information to health professionals and allied services in their community. • Provide local agencies with referral information about allied services such as Medicaid, SNAP, TANF, Healthy Montana Kids (home visiting), immunization programs, Head Start, SNAP-ED and EFNEP, local food banks, etc. 4. Statewide Meetings and Workshops • State WIC Office staff will attend appropriate statewide meetings to share the WIC Program and the services it provides either through presentations or tabling/sponsorships 5. State WIC Outreach Coordinator • The State WIC Office will maintain the role of Outreach Coordinator who will: o Complete pre-monitoring evaluation of local activities and annual outreach efforts. o Provide local agencies data, support and technical assistance on participation in relation to outreach. o Work with contracted marketing company and state print and graphics department on communications, material development and logistics.

o Work closely with stakeholders and partners to coordinate services, projects, and initiatives that are mutually beneficial. o Implement activities within strategic plan related to recruitment, retention and quality improvement. 6. Legislative Queries • Provide the Montana Congressional delegation information about WIC upon request. • Provide the state policy makers with information about WIC’s contribution to the health of women, infants, and children upon request. 7. Notice to the General Public • In June of each year, the Montana WIC Program will publish in the Sunday edition of all major newspapers in the state a public notice requesting comment on the development of the State WIC Plan for the upcoming fiscal year. • The published notice for WIC comments will include a statement to the effect that copies of existing state plans are available online at wic.mt.gov • This notice will allow comments to be received in writing up to the close of business 30 days after publishing. o Submission of comments should be addressed to: WIC Section Supervisor Early Childhood & Family Services Division Department of Public Health and Human Services PO Box 4210 1625 11th Ave., Basement (USF&G) Helena, MT 59604-4210 • The WIC Section Supervisor will receive and review each written comment and acknowledge within 10 days of receipt. o A record of comments received and acknowledged will be included as an appendix in the final approved State WIC Plan. • The WIC Section Supervisor will incorporate such comments as appropriate.

Section III: State Agency Procedure Manual XI. State Civil Rights A. Program Complaints Purpose The Montana WIC Program has an established process for accepting and resolving all program complaints. Policy It is the policy of the Montana WIC Program to accept all complaints regarding the WIC Program and to resolve them accordingly. 1. Complaints • All complaints will be recorded using the Program Complaint Form located as an attachment to the State Plan and linked on our www.wic.mt.gov website. o Anyone may complete the form and submit for review. o All complaints will immediately be sent to the State Office for review and follow-up. • Information submitted must be sufficient to clearly identify all parties involved. However, complainants may choose to remain anonymous. o Use the Program Complaint Form to collect the following information:  Date, time, location, and persons involved in the incident  Name and signature of person taking the complaint and making the complaint (if not anonymous)  Summary of the incident • If the State Office determines the complaint may involve discrimination or a violation of civil rights, the complaint will be forwarded to USDA Office of the Assistant Secretary for Civil Rights and Montana DPHHS Human Resources Civil Rights/EEO Specialist. o The complaint will be logged on the Civil Rights Complaint log on at the State Office and tracked through resolution. o If the State Office determines the complaint does not involve a violation of civil rights, the complaint will be logged and processed at the State and Local level, depending on the nature of the complaint. o All complaints will be initially followed up upon withing three days of receipt by the State Office. • If the complaint involves potential fraud or abuse by a participant, retailer or WIC staff member, the Program Compliance Form will be used to document the investigation and next steps. • If warning, counseling, or disqualification is determined to be the outcome for a participant, the Local Agency will be sent all the information to complete the activities, document in the chart, and report back to the State Office. • The State Office will handle all financial penalties (restitution) or retailer disqualification actions • Appropriate parties will be notified as needed (i.e., legal, law enforcement, USDA, etc.)

Section III: State Agency Procedure Manual IX. State Food Delivery A. Food Delivery System Purpose

This policy describes the WIC benefit food delivery system used by the Montana WIC Program. Policy It is the policy of the Montana WIC Program that grocery retailers are used for redemption of WIC food benefits. Direct distribution will be used for medical foods and formulas not readily available in the retail system. 1. Authorized Vendors • Only those vendors authorized by the Montana WIC Program may process eWIC transactions and redeem food benefits. o A current list of Montana’s WIC-authorized vendors is available on the Montana WIC Program’s website. 2. Participants • Participants shall receive the WIC Program’s supplemental food benefits free of charge. • WIC food benefits must be redeemed in person at a Montana WIC authorized vendor unless a waiver or exception is in place by the United States Department of Agriculture (USDA). 3. State WIC Agency Responsibilities • Provide a uniform WIC food benefit which is in the form of an eWIC card. This benefit is used by all local WIC programs in Montana. • Maintain an inventory of eWIC cards to distribute to local agencies as needed. • The WIC food benefits are processed through the Federal Reserve System to Solutran, Minneapolis, MN, with whom the State WIC Agency contracts. The bank will provide reimbursement to the vendor within 3 business days of the transaction. • Maintain a contingent revolving fund for the WIC Program at Solutran. Each day the bank presents the State with a statement showing the value of benefits paid. The bank is reimbursed for this amount using a wire transfer system. 4. EBT Benefit Processing The Montana WIC Program will start to review and plan for a new EBT processor contract at least two years before the current contract expires. This allows time to determine what changes need to be made to the contract and to have the new contractor selected with no interruption in service. • The contract will be a sealed bid process, opened to all qualified institutions. The term of the contract is a minimum of three years, with three one-year extensions, based on the mutual approval of the Department and the contractor. 5. Current eWIC Processor Contract • eWIC processing services are provided by Solutran, 13305 12th Ave. N. Minneapolis, MN 56253. The current contract’s term expires September 25, 2025, and will be extended to accommodate the transition to Conduent EBT processing services by September 30, 2026.

6. Direct Distribution • When a medical/exempt formula or nutritional is not available through a local authorized retailer, the local agency will order the prescribed product through the State Office Nutritionist(s). o The Formula Order Form will be completed and emailed to the montanawicprogram@mt.gov address to be processed at the State. • The State Office Nutritionist will place the order with the manufacturer directly, or with state authorized vendor, and have the product(s) shipped to the local agency. Shipping to a participant home is an option in extenuating situations, such as lack of transportation. o The State Agency has a tracking system for formula ordering which includes maintaining purchase order forms or invoices electronically and a spreadsheet for communication between fiscal and nutrition staff. o The State Agency has contracts in place with all major formula manufacturers to receive discounts where applicable. Agreements are also in place to be able to return unopened formula where applicable.  The State only orders quantities appropriate for issuance, rather than in bulk as the need for specialized products often change and we aim to reduce waste of resources. o Montana also participates in the Minnesota Multistate Contracting Alliance for Pharmacy (group purchasing), or MMCAP. Any product available via MMCAP for WIC benefit fulfillment may be ordered using this agreement and system. • Formula may be ordered and received at the State Office when distribution issues have been identified. All formula at the State Office will be logged in inventory, stored in a locked/secured location, and at room temperature or temperature indicated on product. • The formula will be received by the local agency and directly issued to the participant at the earliest possible time. o The participant must provide a signature in receipt of the product which will be scanned into the participant chart for monitoring and tracking and/or the local agency staff who issues the product will document in chart the amount of product issued (with all related details for tracking). o The product will be stored within the clinic, in a locked/secure location and at regular room temperature until issued. o Local staff will log formula received, issued, and destroyed for inventory and tracking purposes on the Formula Tracking Log.

Section III: State Agency Procedure Manual IX: State Food Delivery C. Formula Recall Procedures Purpose To help guide the state agency processes during a formula recall and possible subsequent formula shortage. Policy In the event of a formula recall, the state agency will minimize the negative impact of program disruptions to WIC operations and services and ensure the availability of authorized supplemental foods to the extent feasible. 1. Formula Recall Process - In the event of a formula recall, state office staff will confirm the recall o There are no requirements that the formula company must follow when informing the state WIC office. o Historically the state office has been informed through social media, local agencies, or news reports. - State staff will contact the recalled formula company’s representative to confirm that a specific formula has been recalled and other pertinent information: This could include: o Lot numbers, batch numbers, dates of purchase, can size and variety. o How the formula should be returned.  The company typically puts the instructions for returning the formula on their website. They typically give an address to send the returned formula to. o What to do if the recalled formula has been consumed.  The company typically gives a number to contact or to contact your medical provider if you have consumed the formula. - The State WIC Director will delegate the following duties to state staff: o Notify local agencies initially. o Write interim guidance for the local agencies. o Notify the WIC vendors initially. o Research formula substitutions that could be provided.  For contract formulas a waiver from USDA may be available.  For specialty formulas a comparable option may be available on the WIC formulary. o Messages to share with participants on:  Public facing website  WIC shopper app  Local agency and state agency social media pages o A point of contact for questions from the local agencies will be designated.  In some situations, hosting daily informal update calls with the local agencies is appropriate o A point of contact to answer calls from the public will be designated.

2. Coordination and Communication - Communication plan o FNS  The regional office will be notified of alternate operating procedures o Participants  Any participant receiving formula will be notified via text message or other direct means based on available technology o Local Agencies  Notifications and updates will be provided by email, newsletters, and conference calls as appropriate. o Vendors  Email alerting WIC Vendors should be sent. • Vendor initial email should include: o Notify them of what the recall was. o Give them specifics on what has been recalled. o Remind them that due to their Vendor agreement, they should treat WIC participants the same as other customers.  Vendor initial email recipients should include: • Corporate vendor representatives • All active and authorized vendors  Calls from stores are expected. • Communicate instructions to the stores about what other formulas the participants could purchase and when to contact their WIC office to change their benefits. 3. Food Management - To ensure that participants have alternate infant formula and exempt formula options during a formula recall, a list of similar alternate formulas will be used. - In the instance of a formula recall, alternate can sizes and non-contract formula will be issued as needed. o State office staff may order non-contract formula from manufacturers or other vendors for direct distribution as needed o UPCs for alternative formulas will be activated in the MIS

Section III: State Agency Procedure Manual IX: State Food Delivery B. Montana WIC Approved Foods Purpose This policy describes the process used by the State WIC Office to determine authorized supplemental foods, and ensure appropriate supplemental foods are available to WIC participants. Policy The State Office will conduct an annual review of the Montana WIC Approved Food List and will ensure the Universal Product Code (UPC) database accurately reflects Montana WIC Approved Foods. 1. Universal Product Code (UPC) Database • The UPC database is the list of all specific food items available for purchase with WIC benefits. Stores use this database to approve or deny WIC purchases at their Point of Sale (POS). • UPC database maintenance: o The State Office will accept ongoing UPC submissions via:  Montana WIC Portal- Healthy Together App  email sent to the State Office: wicupc@mt.gov o The State Office will review requests within 3 business days.  Items must meet federal WIC food regulations to be considered. a. All UPC submissions will have nutrition requirements verified with manufacturer information. b. If the item meets criteria in the currently approved food list, the State Office will enter the item into the UPC database, which will be available for vendors to download to their POS within 48 hours.  The Approved Product List (APL) will be updated on the wic.mt.gov website bi-weekly to reflect changes that have been made to the UPC database.  If the item does not meet the criteria for the current food list, but does meet the criteria within the federal regulations, the item will be considered during the next food list update review process. 2. The WIC Approved Food List • The WIC Approved Food List describes the size, type, brand (as applicable), and variety of WIC authorized foods and is available in print or electronic format. o Local Agencies use this list to educate WIC participants of WIC authorized foods. o WIC participants use this list to easily identify WIC authorized foods while shopping. • The State Office will review and revise the WIC Approved Food List annually. In addition to the federal WIC food regulations, the following will be considered when revising the food list: o Cost of product, feasibility of UPC collection and maintenance, and local availability. o The annual review will consider all submissions which meet the federal criteria submitted by March 15th of each year for an effective date of October 1st. • The revised WIC Approved Food List will be made available by July in both English and Spanish. o An electronic version will be posted on the www.wic.mt.gov website.

o Hard copy food list documents will be directly mailed to Local Agencies for distribution to participants.  Spanish, or other language translations, are available upon request by Local Agencies.

Section III: State Agency Procedure Manual VI. State Food Funds A. Benefit Management and Reconciliation Purpose The Montana WIC Program is required to reconcile all benefits issued and redeemed in order to identify their disposition. Policy The Montana WIC Program contracts with a financial institution independent of Montana government to process benefits and follows an established plan for the financial management of benefit redemption. 1. Reconciliation of WIC Benefits • At the time of transaction, validations will occur to ensure that only WIC authorized foods currently in the participants benefit package are redeemed. • Requested prices for WIC foods are sent to the bank at the time of the transaction. Those prices are compared against the item’s Maximum Allowable Reimbursement (MAR) to establish a settled price, which is the price paid to the retailer. When the bank completes a payment, rejection, or an adjustment transaction, a record is written to an output file and is sent to the WIC system. • A monthly closeout is reported on the FNS-798 (Monthly Financial and Program Status Report). The information for any closeout month includes a disposition for every issued WIC benefit as redeemed, expired, voided, or payment has been stopped. • Records in support of the FNS-798 are maintained in the State WIC Office.

Section III: State Agency Procedure Manual VI. State Food Funds B. Cost Containment Purpose The Montana WIC Program will efficiently use funds to serve the maximum number of participants through a variety of cost containment approaches. Policy The Montana WIC Program participates in an infant formula rebate contract and maintains competitive pricing criteria. 1. Infant Formula Rebate Montana participates in the Western States Contracting Alliance – National Association of State Procurement Officials (WSCA-NASPO) for infant formula rebate. WSCA-NASPO will 1) identify the states in the alliance, 2) verify that no additional states are added to the WSCA-NASPO infant formula cost containment bid solicitation between date of bid and end of contract, 3) read opened bids aloud publicly on the date bids are due, and 4) allow a minimum of 30 days between publication of solicitation and due date of bids. At the time the WSCA-NASPO bid process is begun, Montana will review the process for these items: • The Montana WIC Program is entered into a competitive sole-source contract for approved and authorized infant formula. The foods procured will include milk and soy-based infant formulas in concentrate, ready-to-feed, and powdered forms. • All manufacturers registered with the United States Department of Health and Human Services (DHHS) whose products fulfill the Infant Formula Act requirements have been offered the opportunity to bid on the initiative. In compliance with 7 CFR parts 3017, certification will be included in contractors’ agreements that they and any subcontractors have not been debarred or suspended. • All manufacturers registered with the United States Department of Health and Human Services (DHHS) whose products fulfill the Infant Formula Act requirements may sell special formula to Montana WIC participants through participating retailers or by direct purchase whether they offer a rebate on WIC infant formula. • Rebate Initiative o The rebate initiative is implemented statewide. o Under this initiative, part of the cost of infant formula provided by the Montana WIC Program is rebated by eligible providers allowing WIC to serve additional participants. o Calculations  The Montana WIC Program calculates the number of cans of formula, by brand and type, purchased each month.  Claims will be filed monthly with rebate values to DPHHS due in 30 days from receipt of invoice. All claims submitted by DPHHS will be sent within forty-five (45) days of the end of each month. o Contracts

 Any contracts signed with companies to implement this initiative shall stipulate that the products meet the provisions of the Food, Drug and Cosmetic Act as it relates to infant formula. o Time Period  WSCA-NASPO has a contract for milk and soy based infant formulas with Abbott Nutrition. The term of this contract is from January 29, 2019 to January 28, 2025. 2. Competitive Pricing • Competitive pricing fosters financial integrity and the most efficient use of WIC funds, which enables the program to serve the WIC participants with the current food budget. All retailers are held to competitive prices within their assigned peer group. Each WIC food item has a Maximum Allowable Reimbursement (MAR) for each peer group. MAR prices are calculated on an ongoing basis by averaging the requested prices for each item and adding a peer group specific buffer to that average. o If a retailer’s requested price is greater than the MAR, their payment will be automatically adjusted to the MAR amount.

Section III: State Agency Procedure Manual VI. Food Funds Management C. Participant Priority Ranking System Purpose To ensure local agencies serve the highest priority WIC participants when the maximum participation level has been reached. Policy Each participant has a priority level assigned to them when they are certified in the program and appropriate risk codes have been assigned. This priority system will guide the state and local programs in ensuring the highest priority participants are served if maximum caseload is reached and a waiting list has been implemented. 1. Priority System • The State will use the following priority levels: o Priority I: Pregnant women, breastfeeding women and infants at nutrition risk as demonstrated by hematological or anthropometric measurements, or other documented nutrition-related medical conditions which demonstrate the person’s need for supplemental foods. o Priority II: Except those infants who qualify for Priority I, infants (up to 6 months of age) of women who participated during pregnancy, and infants (up to 6 months of age) born of women who were not WIC participants during pregnancy but whose medical records document that they were at nutrition risk during pregnancy due to nutrition conditions detectable by biochemical or anthropometric measurements or other documented nutrition-related medical conditions which demonstrated the person’s need for supplemental foods. o Priority III: Children at nutrition risk as demonstrated by hematological or anthropometric measurements or other documented medical conditions which demonstrate the child’s need for supplemental foods; postpartum participants pregnant at 20 years of age or under. o Priority IV: Pregnant women, breastfeeding women, and infants at nutrition risk because of an inadequate dietary pattern, migrant status, or homelessness. o Priority V: Children at nutrition risk because of an inadequate dietary pattern, migrant status, or homelessness. o Priority VI: Postpartum women at nutrition risk.

Section III: State Agency Procedure Manual III. State MIS A. Information Services Purpose This Section provides a description of the Information Services operations. Policy The WIC Information technology (IT) staff is responsible for the day-to-day activities of the major computer systems supporting the WIC program. 1. Computer Systems Support • WIC IT provides hardware and software to sustain WIC operations in Montana. o Hardware and software provided may vary depending on whether a local agency uses the State or Local network. Refer to contract for more information. • WIC IT is responsible for testing the management information system (MIS) software. • WIC IT maintains SPIRIT, Spirit Web (SWEB), and related processes to ensure system up-time and the proper flow of data. 2. Help Desk Support • WIC IT provides helpdesk support to State WIC Office staff and Local Agency WIC staff related to programmatic software applications, such as our Management Information System (MIS). The helpdesk number is (1-800-433-4298, Option 1) and the email address is WicHelp@mt.gov. • For agencies on the State network experiencing issues outside of WIC program specific applications and sites, contact the State Help Desk at (406) 444-9500. • For agencies not on the State network, local IT should be contacted for any hardware or software issues outside of WIC specific applications and sites. 3. Reporting • Approved reports are run at the request of data stakeholders and may include any information stored by WIC systems. As the WIC Data Owner, the WIC Director is responsible for approving all data agreements and releases of information. • Federal regulation and MOUs will be referenced in determining how data will be shared. • Reports and data containing sensitive information will be shared securely, using Tableau or the State of Montana File Transfer System.

Section III: State Agency Procedure Manual X. State Monitoring and Audits A. Monitoring Purpose Ensure program compliance, quality and integrity through desk and on-site monitoring processes. Policy The State WIC Office monitors at least 20 percent of all independently operating WIC clinics within each local WIC agency at least biennially to review compliance with federal regulations, state policies and procedures, and contracts. 1. State WIC Office Responsibilities • A monitoring schedule for the 12-month period of the Federal Fiscal Year will be drafted by July 31st of the previous fiscal year. The needs and schedules of each local agency are accommodated when possible. • The State WIC Office will notify local agencies of travel dates, clinics to be visited, tentative arrival and departure times, items requested to be submitted 30 days prior to visit, and state staff assigned to the monitoring in a letter at least 60 days before the scheduled visit. o If a local agency operates a Breastfeeding Peer Counselor Program and/or a Farmer’s Market Nutrition Program (FMNP), these will be reviewed during the regular program monitoring using additional materials specific to those programs. • Provide updated monitoring forms for use during the review and during self-monitoring in the state plan which is posted on the state’s website. • State WIC Office staff will review participant records prior to the local program onsite review. • State Office staff will perform onsite monitoring using standard forms to observe the overall clinic environment, local agency processes, and participant appointments. Follow-up on items found in pre-monitoring activities will also be completed onsite. o If appointments or activities are not available for actual observation, the monitoring staff will interview local agency staff on their processes for validation of compliance and understanding. • The state staff will facilitate completion of a monitoring report, scoring matrix, and formal cover letter to be sent no more than 30 days after the onsite monitoring visit. • The local agency shall submit a Corrective Action Plan (CAP) addressing all the findings in the report within 30 days of receipt of the monitoring report. The CAP will be sufficiently detailed to ensure that the finding area will be resolved by local agency training, resource development, or process changes. • State staff will review and either approve or deny the submitted CAP within 30 days of receipt. • The local agency shall submit proof that CAP activities were completed via CAP Verification within 60 days of CAP approval letter. • State Office staff will review and either approve or deny the submitted CAP Verification within 30 days of receipt.

• Appropriate follow-up to finding areas will be completed on schedule (based on tier) throughout the following 2-year cycle until the next scheduled monitoring evaluation. • The State WIC Office will provide technical assistance and training to local agencies when necessary to resolve areas of non-compliance. • The State WIC Office will inform USDA of unresolved problems, delays or adverse conditions found during the monitoring process. 2. Monitoring Forms/Reference Material • Forms and processes used for biennial local agency monitoring will remain set for each two-year monitoring cycle, including: o Monitoring- Breastfeeding Peer Counselor Program (BFPCP) o Monitoring- Financial Questionnaire o Monitoring- Chart Review Areas Explained o Monitoring- Chart Review Form o Monitoring- Farmers Market Nutrition Program (FMNP) o Monitoring- On-site Observation for Clinic o Monitoring- On-site Observation for Appointments o Monitoring- Pre-Visit Worksheet o Monitoring Process • Additional resources may be located on eLearn or sent directly to the local agency while monitoring, including: o Scoring Matrix (small, medium, or large version) o Corrective Action Plan (CAP) and Verification Template o Monitoring Process Flowchart

Section III: Local Agency Procedure Manual III. Local Monitoring and Audits B. Records Management Purpose To ensure The State WIC Office is following a standardized records retention procedure. Policy The State WIC Office will manage the records within their office in accordance with the procedures outlined below. 1. Destruction of Records including sensitive or confidential information: • Will be shredded, incinerated or electronically archived by WIC staff or contracted shredding company. • These documents will be referenced for updated destruction date determination with each purging of State records. 2. Record retention timeline will be determined for each type of document according to either (whichever is longest or most relevant to the document type): • USDA/FNS regulation; • Department of Administration record retention policy; and/or • Master Contract

Section III: State Agency Procedure Manual V. State Nutrition Services and Administration (NSA) A. Financial Management Services Purpose This policy provides a description of the State Agencies methodology in determining funding disbursement. Policy The State WIC Office will work with the appropriate state and local agency staff to ensure fair and appropriate funding to all local agencies. 1. State Responsibilities • Develop and manage annual budget for State Nutrition Services and Administrative (NSA) funds, including projected operating costs at the State and values for local agency contracts. • Receive, review, and approve, deny, or request edits on invoices and expenditure reports within 30 days of receipt. o Local programs must send in expenditure reports for the previous month’s actual expenses by the 28th of the month, unless other arrangements have been made. • Make drawdowns against the letter of credit from the USDA. Funds drawn are based on current average expenditures for the state WIC agency as reflected in the SABHRS System, and on current requests for reimbursement from local programs. A request is made to USDA for the estimated amount needed for no more than 3 days of operation. • Maintain documented, accurate and ongoing reports of program expenditures via the SABHRS system. Financial records are maintained which account for all expenditures and letter of credit withdrawals for the Montana WIC Program. • The SABHRS System meets all basic accounting principles as outlined in OMB Circular A-102. The accounting system complies with all general legal provisions and fully discloses the financial position and results of financial operations of the WIC Program. o The accounting system is organized on a fund/account basis (accounting entity). An accounting entity is defined as an independent fiscal entity with a self-balancing set of accounts provided to record assets or other resources together with all related liabilities, obligations, reserves, and equities which are segregated for the purpose of carrying on specific governmental activities or attaining certain objectives in accordance with specific regulations, restrictions, or limitations. o Financial records and reports are prepared at least monthly and at the close of each fiscal year covering all accounting entities and financial operations of State government. o Expenditures are charged to the fiscal year in which they were incurred. Expenditures are recorded based on valid obligations when contractual agreements overlap fiscal periods. o Obtain prior FNS approval on behalf of local agencies requesting to use NSA funds for the following:  Automated information systems, IAW Updates to Thresholds and Procedures for WIC MIS/EBT Planning and Procurement Documents Requiring FNS Approval,  Capital expenditures over $10,000  Non-Computer Equipment, expenditures over $25K per item

2. Local Agency Funding and Contracts Process • General Information o Funds for local programs are from USDA, Food and Nutrition Services, and distributed through the Mountain Plains Regional Office and the Montana State DPHHS. o All funding is appropriated on a federal fiscal year (FFY) and contracted to local agencies based on the FFY. Carry over of funding at the local level is not allowed. o A funding formula is used to project equitable values for local agency contracts; however, these values may be adjusted based on need, funding available, or other factors. o Contracts may be modified, or amended, mid-year. • Local WIC Program Contracts/Task Orders o Local Programs contracted under the government to government 7-year Master Contract with the Department of Public Health and Human Services (DPHHS) will receive a Task Order (TO) which is renewed annually or bi-annually for counties and tribal programs. o Local WIC Programs not covered under the DPHHS Master Contract process will be considered via the State mandated competitive procurement request for proposal (RFP) process. o An application for a new program may be submitted at any time and will be considered according to the associated policy (Section II. Local Organization and Management (IV), policy C. Local Agency Selection). • Equitable Funding Formula o A funding formula is established by the State WIC Office in conjunction with state and local staff. Local program budget allocation is primarily based on “per participant funding”. o Other factors contribute to the formula and are subject to change. Examples include technology support, training funds, dietitian services, performance measures, and outreach activity funding. o If an agency’s needs are less than the calculated funding formula amount, the remaining amount will be reallocated into the formula for agencies who have a greater need. If an agency’s needs exceed the funding formula value and additional funding is available through reallocation (funds not needed by other agencies), the award will be considered on a case- by-case basis considering multiple factors which may include review of the proposed budget and placement in the Affirmative Action Plan. Contracting Timeline Contracting Timeline Month(s) Activity Party Responsible February- March Develop draft funding formula for following federal fiscal year(s) Initiate RFP activities for competitive awards (as needed) State Office and Local Agency Leadership April Send budget, staffing and local role spreadsheet for completion by local leadership, or contract liaison State WIC Director

May Review proposed budgets and finalize funding formula, share with local agencies Hold annual fiscal training with local agencies State WIC Director June Send forms through DPHHS channels for approval to administer funds via contracts State Director and fiscal staff July Develop and send task order and contract amendment drafts for review State Director and fiscal staff Early August Contracts sent to local agency contract signor for signatures State fiscal staff to send to counties; Director’s office staff to send to Tribal agencies; Department of Administration to send to other contractors awarded through RFP process September 30th All signed contracts, sub-contracts, MOUs, and other supporting documentation due to State Office Local Agency leadership & fiscal staff October 1st Contract start date all

Section III: State Agency Procedure Manual II. State Nutrition Services A. Nutrition Services Purpose This Section provides a description of the Nutrition Services Unit responsibilities. Policy The Nutrition Services unit of the State WIC Office is responsible for ensuring that the nutrition component of the WIC program follows the Federal Regulation. 1. State Responsibilities • The Nutrition Services Section (Clinic Services Team) is responsible to: o Develop and coordinate the nutrition and breastfeeding education component of the Montana WIC Program including section goals for program operations. o Update and maintain eligibility criteria documentation including policies and resources. o Provide technical assistance, oversight, and monitoring of eligibility and integrity activities for local agencies. o Collect and analyze program nutrition data for use in program planning and evaluation. o Coordinate with partners and stakeholders to improve the food and nutrition assistance systems in Montana. o Collaborate with partners and stakeholders on quality improvement, program engagement, and setting up effective referral systems. o Provide training and technical assistance to local agency staff on nutrition education and management of breastfeeding. o Identify or develop resources for nutrition education and breastfeeding promotion and management. o Establish standards for providing nutrition and breastfeeding education, promotion, and support. o Develop and implement procedures to ensure that nutrition education is offered to all participants or the parent/guardian of all infants and children; and o Evaluate local agencies nutrition education activities (including those for breastfeeding) and ensure compliance with the nutrition education provisions in the Federal Regulations and State Plan.

Section III: State Agency Procedure Manual IX. State Organization and Management A. Appeals by Local Programs/Fair Hearings

Purpose Local WIC programs have the right to request a fair hearing review from the State WIC Office due to notification of certain adverse actions. Policy The Montana WIC Program will provide, upon request, a full administrative review fair hearing to a local agency who has received adverse actions. 1. State Responsibilities • The State WIC Office will advise the aggrieved WIC agency of their rights under federal regulations. 2. Administrative Review Request • The State WIC Office, upon request for an administrative review (hearing) by a local WIC program, will schedule an administrative review and inform the local WIC program of the time and place, giving the local WIC program 10 days advance notice • An administrative review will be provided by request if the adverse action included: o Denial of application o Disqualification o Suspension, and/or o Sanctions that affect a local agency’s participation • An administrative review will not be provided if the action is the result of: o The expiration of the agreement with the local agency, or, o Montana state procurement procedures/restrictions are applicable to the process of local agency selection. o The Office of Fair Hearings is part of the Department of Health and Human Services (DPHHS) Office of Administrative Hearings. They are located at PO Box 202922, Helena, MT 59620, and their contact phone number is (406) 444-2470, or email hhsofh@mt.gov. 3. Administrative Review Decision • The administrative review will be conducted in Helena and the local agency will be informed in writing of the decision and its basis within 60 days of the date of the request for a hearing. The hearing will be conducted by a fair and impartial official, whose decision will rest solely on the evidence presented at the administrative review and statutory and regulatory provisions governing the WIC program. 4. Administrative Review Procedure • The procedure for the administrative review will provide at a minimum to the local WIC program:

o Ten (10) days advance notice of the time and place of the administrative review to provide all parties involved with enough time to prepare for the hearing. o The opportunity to present its case. o The opportunity to confront and cross-examine adverse witnesses. o The opportunity to be represented by counsel, if desired. o The opportunity to review the case record prior to the administrative review; and o The opportunity for two rescheduled hearing dates. 5. Adverse Actions • Adverse action taken by the State WIC Office will be postponed until an administrative review decision is reached. All appellants denied program benefits at the State level will be informed in writing, along with the decision of the administrative review officer, of their right to appeal the decision to a District Court within 30 days of receiving the written notice. 6. Advance Notice • When possible, local programs will be given 60 days advance notice of any adverse action, including written notice of the action, cause(s) for, and the effective date of the action.

Section III: State Agency Procedure Manual IV. State Organization and Management C. Disaster and Security Procedures

Purpose To provide direction for assessment of an emergency or disaster situation and options for delivery of WIC services. Policy The state agency will continue to provide services in the event of a disaster or emergency. 1. Definition of Disaster • Disaster means a sudden, calamitous event that seriously disrupts the functioning of a community or society and causes human, material, economic or environmental losses that exceed the community’s or society’s ability to cope using its own resources. Examples: Natural disaster (tornado, flood, wildfires), pandemic, bioterrorism • The state agency will determine if an emergency period or supply chain disruption exists by verifying with the State Disaster and Emergency Services Division. 2. WIC’s Role in an Emergency or Disaster • The WIC Program serves a specific population with special nutritional needs. The WIC Program is not designed or funded to meet the basic nutritional needs of disaster victims who would not otherwise be eligible for the Program. WIC is not to be considered a first-line defense to respond to the nutritional needs of disaster victims, including the provision of infant formula. • There are important ways the WIC state and local agency personnel can contribute to a disaster relief effort. The primary functions are: a. Continued benefit delivery to WIC participants b. Outreach to potentially eligible individuals c. In addition, the WIC Program may serve as an information and communication source for WIC families and an ongoing source of referrals to other emergency services. • This procedure outlines the processes to follow when a disaster or other emergency situations may interrupt WIC services. 3. Replacement of WIC Food Instruments and Foods Destroyed During a Disaster • WIC is currently unable to replace food or formula that has been purchased and destroyed during a disaster but will follow the guidelines from USDA WIC Disaster Guidance Coordinating during WIC Services Disaster o Replacement of food benefits redeemed but destroyed may only occur if:  The replacement of redeemed food benefits does not result in the replacement of prior month(s) benefits.  If the participant has benefits remaining in a 3-month issuance cycle, the State agency has the option to issue the remaining benefits to replace the lost/destroyed food.

• Referrals should be made to other disaster assistance resources such as food banks, Red Cross, D-SNAP, etc. 4. Disaster Procedures and Contact Lists • All State WIC staff will review the developed plan annually. • The State Agency and Local Agencies will maintain current contact lists for the primary contacts for each Agency. • The State Agency list should include contacts for: o State Agency staff and DPHHS points of contact o USDA Regional office contacts o Local WIC Agencies primary contacts o Infant formula manufacturers o WIC Vendors • Designated emergency contacts within the state office with be communicated with the RO and local agencies o State WIC Directorwill serve as the main emergency contact o Assistant WIC Director will serve as the emergency contact to address the needs of participants receiving food package III o Vendor Coordinator Lead will serve as an emergency contact to address vendor needs specific to WIC 5. Notifications and Requirements • The State Agency will contact the USDA Regional Office to keep them informed of disaster situations in Montana. • Local Agencies should contact the State Agency as soon as safely possible after a disaster and provide a report on the following: o the impact of the disaster on the local agency o status of staff safety o damage to locations o damage to equipment o clinic and Agency scheduling changes and updates, o other action taken to ensure continued services o updates to Agency primary contact information. • The State Agency will work with the USDA RO on necessary waivers or adjustments needed to WIC procedures. • The USDA Regional Office must be contacted prior to suspending WIC operations. 6. Communication & Outreach Plan • Local Agencies will receive regular and ongoing communication from the State Agency through email, conference calls, and video calls. • Information for WIC clients will be posted on the State WIC webpage, through social media sites, text messages, and other available media. Local Agencies should post information on their own websites or other social media sites. • State Agency guidance and changes to WIC procedures for Local Agencies that must be communicated with urgency will be sent via email

• Local Agencies should develop lists of local resources to refer families to, such as food banks, pantries, other USDA programs including SNAP, community resources, health providers/departments for disease related issues. • The state agency will coordinate with relief organizations and state emergency operation centers as necessary. 7. Operating during an MIS Outage, Partial or Statewide • If the MIS were to become unavailable statewide, and is not immediately recoverable, the State Agency will provide guidance to continue operations in an alternative manner. • Accessing program records in the event of MIS outage o State Agency will notify IT stakeholders  Recover most recent MIS backup  Initiate new MIS environment o State Agency will provide alternate procedures to issue benefits when an MIS recovery is not possible 8. Serving Disaster-Related Evacuees and Applicants • The State Agency will follow all guidance from USDA-FNS related to serving disaster-related evacuees. Those who seek WIC benefits shall be considered special nutritional risk applicants and receive expedited certification processing. • Federal regulations require applicants/participants who have been designated as special nutritional risk applicants be notified of their eligibility or ineligibility within 10 days of the date of the first request for program benefits. These individuals should be served ahead of others seeking benefits. • The Local Agencies must make every effort to certify these individuals immediately or within 10 days of their request for WIC benefits. • Applicants/participants who are victims of an emergency or disaster must be served ahead of others receiving WIC benefits and receive expedited certification processing. 9. Providing WIC Services • The SA will follow USDA-FNS guidance for providing WIC services and education during a disaster/emergency. o WIC Benefit Issuance o Nutrition Education o Mid-certification visit o Breastfeeding support • VOC Issuance o VOC documentation will be provided to WIC participants if requested when a disaster- related evacuation is anticipated o Participants will be notified of VOC options as needed • Local agencies shall continue to provide services per remote certification policies • Local agencies shall submit requests to the SA for health and safety equipment as necessary 10. Benefit Issuance and Redemption • Benefit Redemption o SA will monitor and publicize the availability of WIC approved vendors.

If there are no vendors within Montana that can redeem eWIC benefits, the SA may temporarily authorize a vendor outside of Montana upon special determination. • Food instruments (ie- EBT cards) will be issued via clinic pickup or certified mail 11. Nutrition Services • Nutrition point of contact: State Nutrition Coordinator • Breastfeeding point of contact: State Breastfeeding Coordinator • Adjusting food packages o The SA will allow food package substitutions based on availability of options from APL as approved by FNS o The SA will apply for any needed food package waivers if available • Food Package III o In the event of a disaster or emergency, verbal orders for medical formula or nutritionals will be accepted for 30 days until a written order can be received • Infant formula distribution o To limit the disruption of infant formula benefits in a disaster or emergency, direct distribution of formula or delivery to the participant’s home may be allowed if necessary 12. Retail Viability • In a pandemic situation, most retail stores should remain open, however quantities of WIC foods available on store shelves may be limited or unavailable at certain times based on the public’s shopping patterns. The State Vendor Management Coordinator and local vendor managers will work to assess product availability and work with WIC families to find products as necessary. Specific attention will be paid to the availability of infant formula. • Following a natural disaster, the state agency will establish and update a list of retail grocery stores that remain in operation following the disaster, their operating hours, and an overview of their available stock of WIC approved foods, to the best of the SA ability. The State and Local Agencies will coordinate efforts to share this information with the participants. • Retail purchase is considered nonviable when a significant number of clients are unable to purchase WIC approved foods. The state agency will work directly with individual vendors and corporate offices in the affected chain stores for the status of their outlets in the affected area. Vendor Management • Temporary suspension of vendor requirements o Annual vendor monitoring, training, and compliance inspections may be temporarily suspended with notification from the SA. instructions to LA staff and vendors will be provided as needed. Minimum stocking requirements may be adjusted as needed, per vendor.  Vendors will be required to continue to stock at least two varieties of fruit, three varieties of vegetables, and at least one whole grain cereal.  Vendors will be required to only source infant formula from the SA’s list of approved infant formula suppliers. o Selected vendor application criteria may be temporarily waived, and authorization timelines expedited if new vendors are required for emergency participant access.

Section III: State Agency Procedure Manual IV. State Organization and Management B. WIC Trainings/Meetings/Conferences Purpose To ensure participation in regional and/or national WIC-related meetings and conferences. Policy Public Law 111-296 requires that Federal/State agreements include a provision supporting full use of Federal funds and excluding such funds from State budget restrictions or limitations including hiring freezes, work furloughs, and travel restriction. The following meetings and trainings are attended annually after review and approval according to state level policies and procedures: • Mountain Plains Regional Director’s Meeting o The State WIC Director to attend annually or may send designee. o Additional staff may attend if there are associated meetings for specific roles, such as the Nutrition or Breastfeeding Coordinators meeting. • National WIC Association (NWA) conference(s), including but not limited to: o Annual Policy (or “Leadership”) conference o Annual Education and Training (general) conference o Bi-annual Nutrition and Breastfeeding conference o Bi-annual Technology and Integrity conference • Breastfeeding Learning Collaborative (BLC), which is hosted and sponsored by the WIC Program and Baby Friendly Hospital Initiative funding through DPHHS • Great Beginnings Great Families, hosted and sponsored in part by the State WIC program • Perinatal Mental Health Conference, hosted and sponsored by Healthy Mothers Healthy Babies (HMHB) • SPRIRIT User Group (SUG) Meetings, including strategic planning, business meetings, and ad hoc meetings related to system management o The SUG has several sub-groups and State staff participate in them. It is expected as part of the group that the state representatives will attend meetings scheduled. • Mountain Plains Regional Office Trainings (role or topic specific, as needed) • Nutrition Leadership Network (NLN) o State Director and Assistant Director-Nutrition Coordinator are sponsored by the Western Region of Maternal and Child Health (Title V MCH) program for this nutrition specific training annually. Depending on the agenda, more staff may be able to attend. • Travel in-state for monitoring, training, compliance investigations or technical assistance will be completed to ensure grant requirements and program deliverables are met. • Other conferences, meetings and trainings related to WIC, and role specific competencies or program specific topics, will be considered on a case-by-case basis. • The State may fund local agency staff to attend a conference on a case-by-case basis.

Section III: State Agency Procedure Manual I. State Vendor and Farmer Management A. Vendor Services Purpose This section provides a description of the State Vendor Services Unit responsibilities. Policy The State WIC Office is responsible for ensuring compliance with Federal and State Vendor Management regulations. 1. State Responsibilities • The State WIC Office Vendor Unit assumes responsibility for the management of the following: o Development and dissemination of vendor training and outreach materials o Development and dissemination of Local Agency Retail Coordinator (LARC) training materials o Annual vendor and LARC trainings o Participant and retailer fraud/abuse o Vendor complaints o Annual vendor monitoring visits o Annual High-Risk Analysis, and compliance investigations o Vendor applications, renewals, and contract management o Vendor management policies o New Vendor “Above 50% Analysis” o Vendor cost containment and peer group placements o Reporting WIC vendor data to USDA FNS o eWIC transaction training, technical support, and review o Infant formula rebates

Section III: State Agency Procedure Manual I. State Vendor and Farmer Management B. Retailer Authorization Process Purpose Ensure standard criteria is used to evaluate retailer applications for WIC Program authorization and provide adequate access for participants to redeem food benefits. Policy Retailers must meet the following criteria to be authorized by the Montana WIC Program. All selection criteria must be maintained through the term of the agreement and may be reassessed by the program at any time. This list is not fully inclusive, please refer to the Vendor Agreement and Retailer Reference Manual for all program requirements. Retailers applying for authorization must meet specific criteria to ensure effective program management. These standards will be used to review retailer applications and renewals. 1. Criteria to Become a WIC Authorized Retailer: • Have a Point-of-Sale (POS) system capable of conducting eWIC transactions, this system must: o Be able to download the Approved Product List (APL), and be capable of:  Preventing unauthorized food item purchases.  Preventing the purchase of approved food items not available on card balance. o Provide all transaction receipts (beginning balance, purchased items, and remaining balance). o Meet minimum lane coverage requirements. o Will not charge the WIC Program any third-party processing fees, interchange fees, or ongoing maintenance and operational costs. o Maintain compliance with operating rules, standards, and technical requirements. • Within the last six (6) years, neither the business nor any of its owners, officers or managers has been convicted of or had a civil judgment entered against them for any activity indicating a lack of business integrity. • An owner, officer, or partner of a retailer must not have bought or sold a store to avoid a WIC sanction. • Is SNAP authorized (Supplemental Nutrition Assistance Program, formerly known as Food Stamps), o Vendors must not be in a current disqualification of SNAP or have been issued a Civil Money Penalty in lieu of disqualification. • Always maintain the minimum food stock required by the Montana WIC Program. • Purchase infant formula only from the Montana WIC Program’s approved Formula Wholesaler/ Distributor/Retailer/Manufacturer list to ensure safety of the products.

• Meet and maintain Competitive Price Selection Criteria (CPSC) requirements. o CPSC is a price level retailer applicants must meet to be eligible for the WIC Program and maintain throughout the term of their agreement. o The CPSC is based on average food prices grouped into a market basket price and is specific to each peer group. o Retailers CPSC is re-evaluated six months after initial authorization, and statewide CPSC market basket prices are re-calculated every six months. o If a retailer’s market basket price exceeds that of the retailer’s assigned peer group, the retailer may be authorized by the MT WIC Program if the vendor is needed for participant access. • Agree to accept payment for food prices for no more than the Not-To-Exceed (NTE) price set for each food item. o WIC is federally required to enforce maximum price reimbursements for approved foods as a cost containment measure. These amounts are considered the Not-To-Exceed (NTE) price. When a retailer submits a price greater than the NTE, the state’s EBT processor adjusts the reimbursement to that NTE. o WIC NTE prices are calculated by averaging claim prices per food item (excluding fresh produce). Recalculations occur weekly, and a standard deviation of 2 is added to the average to create the NTE. Items must have at least 10 claims in the last 90 days to be included in the recalculation. If an item’s NTE increases or decreases significantly, the new NTE must be manually approved by WIC staff. The WIC Program reviews its competitive cost system (NTE calculations & peer group placement) every three years. o WIC organizes retailers by size and geographic designation into peer groups, which are used to calculate the NTE amounts. The NTE calculation system and criteria used for peer group placement are reviewed at least every three years. o In the event of a suspected vendor overcharge or payment error, and the vendor has committed a program violation, the WIC Program may delay payment or establish a claim in the amount of the overcharge or error. The vendor will have the opportunity to correct the issue, and the WIC Program must take-action on a questionable payment within 120 days of occurrence. Denying payment or initiating a claim must occur within 90 days of the violation or completion of the review, whichever is later. o The WIC Program will not pay retailers for transactions that occur after the specified period for benefit redemption for values over $500 without first notifying USDA FNS. • May not be a ‘WIC-Only’ store (sell only WIC-approved foods to WIC participants). • May not be a ‘Above-50-percent’ store (stores that make more than 50 percent of their annual sales from WIC purchases). o Montana WIC will continue to evaluate stores on the program to determine if they become an ‘Above-50-percent’ store and disqualify any stores who become ‘Above 50%. • Meet and maintain Produce Mapping requirements o Mapping is the process of matching UPCs of packaged fresh fruits and vegetables to Price Lookup Codes (PLU) for bulk produce on the Montana WIC Approved Product List (APL) in a store’s Point of Sale (POS) system. o All fresh fruits and vegetables rung up with a barcode, including pre-cut and packaged items by the retailer should be mapped. Montana WIC will not authorize a vendor if a potential or real conflict of interest has been

identified by WIC staff. 2. Criteria Waiver Based on Participant Access Determination • In areas where WIC participants have limited access to WIC authorized retailers, some selection criteria may be waived, at the program’s discretion, based on a participant access determination. o In WIC service areas where the total population is greater than 3,000, participant access may be considered inadequate if any of the following conditions apply:  A retailer density of less than 1 store per 200 WIC participants.  WIC participants must travel more than 2 miles to the nearest WIC authorized retailer.  Other conditions exist which makes a retailer located within 2 miles difficult to access. o In WIC service areas where the total population is less than 3,000, participant access may be considered inadequate if any of the following conditions apply: There are no vendors in the area. o Participants must travel more than thirty miles to an authorized retailer. o Other conditions exist which makes an authorized vendor within 30 miles difficult to access. • If a retailer applying to the program is in an area with participant access issues and does not currently have a POS capable of conducting eWIC transactions, a single-function POS terminal may be provided by the State. • If a retailer applying to the program is currently disqualified from SNAP or has been assessed a SNAP Civil Money Penalty (CMP) for hardship, this criteria may be waived if the vendor is needed for participant access. • Within the last six years, if a retailer applicant or any of its owners, officers or managers were convicted of crimes demonstrating a lack of business integrity or had civil judgement entered against them, this criteria may be waived if the vendor is needed for participant access. • No waivers will be made for vendor applicants that do not meet the minimum requirements for stocking of approved foods. 3. Application for Retailer Authorization • Initial applications are accepted on an ongoing basis. • Applications may be requested from the State WIC Office vendor management staff. o An initial screening of the retailer will be completed to ensure the selection criteria are met; this may include:  Consultation with the local agency in the retailer’s region.  Assurance that the retailer has the capability to process eWIC transactions (retailer is responsible to confirm with POS provider).  The MT WIC Program will provide an X9 number to the retailer for their set up with the POS and Third-Party Processor (TPP). o A paper or electronic application will be sent to the retailer for completion and the local agency in the area will be notified by the State office of the application status. • Retailer will complete and submit the application which will be processed within 60 days of receipt. • If the retailer does not meet the criteria for approval, a letter describing the ineligibility will be mailed.

4. Pre-authorization Visit and Inspection • The initial visit to the store by Local Agency Retail Coordinators (LARCs) is to verify that the required WIC food variety and quantity is in stock, and to conduct a test-buy that verifies the retailer’s Point of Sale (POS) can conduct eWIC transactions. WIC staff will also check that dates on foods are not expired, overall cleanliness, and provide the retailer with interactive training on WIC policies and procedures. This visit is arranged after the WIC program receives verification from the retailer that their POS system has been successfully set up to conduct eWIC transactions and a balance inquiry has been completed in the EBT processor’s transaction records. The pre-authorization test buy will include: o Verification that all required receipts are produced (available balance, purchase verification, purchase approved, remaining balance). o Authorized WIC item & unauthorized WIC item.  Authorized fresh produce UPC mapping to comparable PLU.  Authorized item that exceeds available balance. o Paying the difference on a CVB purchase. o Processing a Not to Exceed (NTE) price adjustment. • The report from the pre-authorization inspection visit will be sent to the Montana WIC Program for review. If the report indicates any issues, such as required quantities and variety of WIC foods out of stock, or problems during the test-buy, the retailer will need to provide verification that the issues have been corrected before the store will be authorized. • Approved stores will be sent a WIC Vendor Agreement which must be signed and returned. The agreement will have a maximum of 3 years; but may be shorter to align the retailer's contract period with the federal fiscal year calendar. 5. Preauthorization Interactive Training Requirements The Montana WIC Program will provide training in an interactive format before or at the time of a new vendor’s initial authorization. This training will cover all topics required in annual training for authorized vendors and will provide vendors the opportunity to ask questions and receive immediate answers. • Interactive training will be provided in person and on-site as the priority. • If on-site interactive training is not available alternative means will be provided to ensure that the required topics are covered, and the retailer is afforded the opportunity to ask questions and receive immediate answers. Alternative means include, but are not limited to, over the phone training, or a web-based platform. Over the phone training is considered the training of last resort. • Vendors will be provided with at least one alternative date on which to attend an interactive training. • In all cases interactive training will be documented to verify the time and date the training was provided, the format provided, and the required topics covered, as well as retailer questions and responses. Both the retailer and the trainer will sign and date the documentation form and this will be included in the retailer’s file at the WIC State Office. A copy of the signed documentation form will be provided to the retailer as well. • Completion of this training will be documented on the Vendor Preauthorization Monitoring

Form. • This training will be provided by the Local Agency Retail Coordinator (LARC) for the local WIC agency supporting the retailer. • WIC state agency staff will provide backup support as needed. 6. Initial Retailer Authorization Process • Authorized retailers will be assigned to a Peer Group based on criteria established by the program to ensure competitive pricing and reimbursement. o Peer group placement will be re-evaluated and assigned at reauthorization and as needed when criteria or circumstances change. o Peer group placement will determine the allowable reimbursement for WIC approved items based on average prices and an automatic range determined by the Program. • Upon authorization the retailer will receive an acceptance letter notifying them they are an authorized WIC retailer and what Peer Group they are placed in. The retailer will also receive the following items: o “We Accept WIC Benefits” signs (to be posted in a visible location near all entrances of the business). o Additional copies of the “WIC Approved Food List” (in sufficient quantities to place one at each check stand). o A copy of the Montana WIC Program Retailer Reference Manual. • Once the retailer is authorized to process eWIC transactions, they are responsible for training their staff on eWIC procedures. • In the case where agreements are signed at the corporate headquarters, a copy of the signed agreement may be sent to the store’s manager for their records. • The State will notify the local agency that the retailer has been authorized to participate in the WIC Program and the local agency will notify their participants that they may redeem benefits at this retailer. The State will add this retailer to their list of authorized WIC retailers. • The new retailer will be reassessed six months after authorization to determine if they are an ‘above-50-percent’ retailer. o Once the assessment is completed a letter will be sent to the retailer notifying them of their status. Copies of this letter are retained at the State WIC Office and a copy is sent to the Local Agency in the retailer’s area. 7. Process for Authorization Renewals • The WIC State Vendor staff annually review retailer files due to expireand will send out renewal notices for all retailers with agreements expiring that fiscal year at least six months prior to their agreement expiring. • Renewal notices are mailed annually inviting retailers to renew. o If the retailer chooses to renew their agreement the renewal application must be returned to the WIC State office at least sixty (60) days before their agreement expires to allow enough time to route the renewal agreement for signature. • In addition to maintaining the standards for the initial application, an applicant must also meet the following standards to apply for renewal of their WIC authorization: o Has attended all requiredWIC trainings. o Has successfully resolved all problems brought to their attention by the WIC Program

within a sixty (60) day period. o Has not been disqualified from SNAP or been charged for embezzlement by SNAP. • Retailers applying for renewal authorization must apply within the required timeline. This ensures that they maintain their current authorization. o If the authorization lapses, an initial application must be submitted. • A retailer is not obligated to apply for renewed WIC authorization. A retailer may withdraw from the WIC Program at any time by contacting State WIC staff. • The Montana WIC Program is not obligated to offer a retailer a renewed vendor agreement. 8. Change of Ownership • The authority to participate in the Montana WIC Program is non-transferable. The Montana WIC Program must be notified in writing of any change of ownership. A change of ownership may be, but is not limited to: o A partial change of ownership (i.e., one partner buying out another). o A complete change of ownership (i.e., an outside interest purchases the business). o A change in corporate structure (i.e., going from ‘sole proprietor’ to ‘corporation’). • Whenever the Federal Employer Identification Number (FEIN) changes, the retailer must re­ apply for WIC authorization as an initial applicant. Failure to do so will result in loss of WIC authorization. If it is determined that a business was sold to circumvent a WIC sanction after authorization is approved, the authorization (WIC Agreement) will be terminated. 9. Change of Location • A change of location may affect WIC authorization. The Montana WIC Program must be notified in writing of any change of location. Authorization will not be affected if: • The ownership remains the same. The old location is being closed, and the new location is considered a ‘replacement’ location. • The new location is within a short distance of the old location. • Failure to notify the Montana WIC Program of a change in location may result in loss of WIC authorization. 10. Change of SNAP Authorization • If a WIC authorized retailer’s SNAP authorization changes at any time during the WIC agreement, the Montana WIC Program must be notified either verbally or in writing and provided with an updated FNS number.

Section III: State Agency Procedure Manual I. State Vendor and Farmer Management C. Confidentiality of Retailer Information Purpose The release of confidential retailer information is restricted. Policy Information about any WIC authorized retailer, except for name, address, authorization status, telephone number, website and business email address, and store type, is considered confidential. Release of confidential retailer information is limited by Federal WIC Regulations. 1. Confidential retailer information is available to: • Persons the State Office has determined have a need to know for program purposes because of their direct connection with the administration or enforcement of the WIC Program or SNAP. For example: o Montana WIC Program Local Agency Retailer Coordinator (LARC), or their designee o Contractors hired by the Montana WIC Program to perform compliance investigations o Other WIC State Agencies o Other WIC State’s Local Agencies o Persons investigating or prosecuting WIC or SNAP violations under Federal, State, or local law. o Persons directly connected with the administration or enforcement of any Federal, State law (see notation) Note: A written agreement must be entered into with any non-Federal agency specifying that information provided may not be used or disclosed except for the direct purpose of administration or enforcement of a Federal or State law. o An individual Retailer when subject to an adverse action, including claim information related to the adverse action. 2. Limitations of Information Releases • The Montana WIC Program will apply the same limitations to the use and release of information obtained from SNAP regarding SNAP retailers regardless if the retailer is also a WIC retailer. 3. Authority • The Vendor Manager or the Montana WIC Program Director will determine the conditions under which confidential retailer information is released. • All requests for confidential retailer information must be directed to the State Office. • Requests for confidential retailer information from an entity outside of the Montana WIC Program must be in writing.

4. Timeline • State Vendor staff will respond to the request for confidential information within ten (10) working days except for when legal advice or a legal opinion is sought from the DPHHS legal services. In the event the request for legal services delays the response the Vendor staff will notify the requestor in writing of the delay. No requested response will be delayed beyond thirty (30) days. 5. Documentation • Any request for confidential retailer information must be documented in the retailer’s file by dates, including any action taken, agreement for the information released. State Office staff responsible for each action must sign the documentation.

Section III: State Agency Procedure Manual I. State Vendor and Farmer Management D. Retailer Stocking Requirements Purpose Consistent availability of WIC foods ensures participants can purchase food prescribed on the WIC benefits when they shop at authorized WIC retailers. Policy WIC authorized retailers must stock and maintain a specific minimum quantity of WIC-approved foods. 1. Stocking Requirements • Review attachment Minimum WIC Foods Stocking Requirements for a full description of food items and quantities that must always be maintained in stock. 2. Stocking Exemptions • Retailers who have a small infant population or are not required for participant access may apply for a stocking exemption for infant formula, infant cereal, and infant food. Montana WIC reserves the right to offer stocking exemptions for other foods on a case-by-case basis. • Applications for exemptions are available to retailers by request and will be reviewed and approved on a case-by-case basis at the State Office discretion. o Redemption and/or participant access will be reviewed during the determination. o The State will notify the retailer and local agency of the decision in writing. o Exemptions must be reviewed and renewed with each contract period. o An exemption may be canceled if conditions change during the contract period. • Retailers receiving an infant formula, infant cereal or baby food stocking exemption must post a sign directing participants to the retailer’s contact person for ordering exempt items. • If a participant requests an exempted item from the retailer, the retailer must order the product and make it available to the participant within three business days. o The retailer must continue to order the food items for the participant if requested by the participant. o If the retailer refuses to stock these items for the participant, their stocking exemption will be voided. 3. Stocking Shortages When a shortage is first reported to the state office: • WIC staff will call the retailer to discuss the shortage and the next anticipated delivery date. • WIC staff explain that they are out of compliance with the vendor agreement and will document the conversation in the retailer file. • Within the next 30 days, LARC or state agency staff will perform a reassessment of the store to ensure they meet stocking requirements. • If the store fails to have the required stock, they may be issued a sanction or terminated from the WIC Program. This may be waived if the circumstance is beyond their control (i.e., distribution issue). 4. Infant Formula Purchasing Requirement • To ensure the safety of infant formula, it must be purchased from the Montana WIC Programs list of approved formula distributors. This list is available on the MT WIC website.

Section III: State Agency Procedure Manual I. State Vendor and Farmer Management E. Administrative Review Purpose The WIC Program must impose sanctions on vendors for non-compliance with program regulations, policies, and procedures. Policy A retailer may request an administrative review to contest a punitive decision rendered by the Montana WIC Program. 1. Introduction • The Montana WIC Program will provide, upon request, a full administrative review to a retailer seeking to appeal the following adverse actions: o Denial of authorization based on:  Retailer selection criteria for minimum variety and quantity of authorized supplemental foods  An imposed sanction  Termination of an agreement for cause  Disqualification, and  Imposition of a fine or a Civil Money Penalty (CMP) in lieu of a disqualification. • The Montana WIC Program will provide, upon request, an abbreviated administrative review to a retailer who has received the following adverse actions: o Denial of authorization based on:  Vendor selection criterion for business integrity.  Vendor selection criterion for current SNAP disqualification or CMP for hardship.  State agency-established vendor selection criteria related to WIC vendor sanctions or SNAP authorization.  State agency’s vendor limiting criteria.  Denial of authorization based on the application of the vendor selection criteria for competitive price. o Disqualification based on any of the following:  Trafficking conviction  Imposition of a SNAP CMP for hardship  Disqualification or CMP instead of a disqualification based on a mandatory federal sanction imposed by another WIC State agency.  Application of criteria used to identify vendors that are “Above 50%” vendors or comparable to “Above 50%” vendors.  Termination of an agreement because of a change in ownership, location, or cessation of operations.  A WIC CMP imposed instead of disqualification based on a SNAP disqualification. 2. General Conditions

• At the time an adverse action is invoked, a written notice will be sent to the retailer. The notice will contain the effective date, the procedure to follow to obtain an administrative review (the notice must specify which type of review may be requested) and the timeframe for the request. If the adverse action is related to disqualification, the notice will contain the following statement: “This disqualification from Montana WIC may result in disqualification as a retailer in SNAP. Such disqualification is not subject to administrative or judicial review under SNAP.” • The retailer has sixty (60) days from the date of receipt of the written notice of adverse action to request an administrative review. The request for an administrative review may be made to the Montana WIC State Office. The request may be written or verbal. The Montana WIC Program will determine the type of administrative review. • If a retailer can continue operation as a Montana WIC Retailer during the process of an administrative review, the terms of the Montana WIC Retailer Agreement are still in force and the retailer must comply with the terms. • A disqualification because of a conviction of trafficking will be effective immediately. • If the decision of the administrative review upholds the adverse action, this will be the final action taken by the Montana WIC Program. Any adverse action related to the administrative review which has not already taken effect, must do so on the date the retailer receives the notification of the decision. • The retailer may appeal the administrative review decision in District Court in the First Judicial District of the State of Montana, in and for the County of Lewis and Clark within thirty (30) days of receiving the written decision. 3. Procedure for Administrative Reviews • The Montana WIC Program will set the date for a full or abbreviated administrative review within three weeks of the receipt of the request. • The retailer will be notified in writing within a minimum of ten (10) days in advance of time and place of the full administrative review. • All full administrative reviews will be held in the county in Montana in which the business in question is physically located. Abbreviated administrative reviews may be conducted remotely. • The full administrative review will be conducted by a fair and impartial official according to 7 CFR 246.18 and applicable portions of Title 2, Chapter 4 Montana Code Annotated, whose decision will rest solely on the evidence presented at the hearing and the state’s approved policies and procedures governing the Montana WIC Program. • The abbreviated administrative review will be conducted by a decision maker using the available information to determine whether the State Agency has correctly applied federal and state statues, regulations, policies, and procedures governing the program. The decision maker may be WIC staff, but will be somebody other than the person that made the initial decision on the action. • In both abbreviated and full administrative reviews, the retailer will have the opportunity to: o Review the case file prior to the administrative review; o Retain representation by legal counsel; o Cross-examine adverse witnesses (protection of the identity of investigators may result in the examination being conducted “in camera” or with the witness behind a protective screen);

o Present their case; and, o Reschedule the full administrative review date once upon request. • The retailer will be provided written notification of the decision of the full or abbreviated administrative review within ninety (90) days of the receipt of the retailer’s request for an administrative review. The notification must include the basis for the decision. Failure on the State’s part to meet the decision notification timeframe is not grounds for overturning the adverse action. 4. Denial of Administrative Review The Montana WIC Program will not grant an administrative review if requested by the retailer and the basis of the request is: • The validity or appropriateness of: o Montana’s retailer selection criteria o Montana’s participant access criteria and the participant access determination o Peer group criteria o “Above 50% Vendor” identification methods o Prohibition of incentive items • The determination by the Montana WIC Program as to whether the retailer had an effective policy and program in place to prevent trafficking and the retailer was not aware of, did not approve of and was not involved in the commission of the violation. • Denial of authorization if the State Agency’s vendor authorization is subject to the procurement procedures applicable to the State Agency. • Expiration of the agreement. • Disqualification from the Montana WIC Program because of disqualification from SNAP. • Disputed eWIC payments. • The Montana WIC Program’s determination to include or exclude an infant formula manufacturer, wholesaler, distributor, or retailer from the State Agency list. • The Montana WIC Program’s determination whether to notify a retailer in writing when an investigation reveals an initial violation for which a pattern must be established in order to impose a sanction.

Section III: State Agency Procedure Manual I. State Vendor and Farmer Management F. Use of WIC Acronym and Logo Purpose Ensure enforcement of WIC requirements and protect against infringement of service marks. The WIC acronym and logo are service marks owned by the USDA, and all rights therein and goodwill pertaining thereto belongs exclusively to USDA. Policy Montana WIC authorized retailers and food manufacturers are not permitted to use the WIC service mark or logo to avoid giving the impression that the business is affiliated with or sponsored by the State agency, USDA or the WIC Program. They are permitted to create store shelf tags using the WIC service mark or logo with prior MT WIC State Office approval. 1. WIC acronym, service marks and logo may not be used in a retailer or manufacturer name. 2. WIC acronym, service marks and logo may not be used on a manufacturer’s goods label, packaging, tag, or container. 3. Authorized retailers and product manufacturers may not apply stickers, tags, or labels having the service marks thereon to WIC-approved products. 4. The Montana WIC Program does not issue shelf tags, nor require their use by WIC authorized retailers. However, retailers may use their own generated shelf tags including the service marks to identify WIC-approved products if they have been submitted to the State office and received prior approval. 5. Retailers may use the WIC acronym, service marks and logo in advertising or promotional materials used to inform the public that the retailer is WIC-authorized, such as the “We Accept WIC” decal provided by Montana WIC. Retailers and manufacturer contractors may not use the acronym, service marks and logo in any other advertising or promotional literature unless it is submitted to and approved by the State WIC office.

Section III: State Agency Procedure Manual I. State Vendor and Farmer Management G. Compliance Investigations Purpose Program compliance is mandatory to operate an efficient and effective program. Policy 1. A minimum of five (5) percent of all WIC authorized retailers will receive a compliance investigation annually. High-risk criteria will be applied uniformly to all retailers, and at least the top 5 percent of the retailers deemed to be high risk will be selected for a compliance investigation. High Risk Criteria • State WIC Staff may utilize but are not limited to the following criteria to determine High Risk Vendors: o Statistical analyses, including but not limited to Low Variance in Price and High Average Price compared to Maximum Allowable Reimbursement (MAR) o New Vendors o Participants/staff complaints and/or observations o Vendor history of program violations and/or non-compliance o Vendors using stand beside devices o Previous WIC or SNAP suspension o STAR determination of High Risk o Large number of keyed entries 2. Compliance Investigations • Compliance investigations shall be accomplished by conducting either a compliance purchase or inventory audit at the Program’s discretion. • A compliance purchase is defined as a covert purchase made using an eWIC card by WIC staff, or their contracted designee. The purchase is made without notifying the retailer’s management or staff. • Pre-purchase Procedure: o Prior to the store visit, the compliance investigator may review the retailer’s file to learn if the retailer has a history of non-compliance or stocking exemptions. o State WIC staff will use the MIS to issue benefits on an eWIC card using the compliance buy function in the MIS. o State WIC staff will manage the compliance buy eWIC cards, and will distribute them to contractors and staff as needed. o Any staff or contractor who will complete a compliance investigation, training and education will be provided and will include (but is not limited to) the following topics:  Steps in the compliance buy process.

 Process for completing the Compliance Buy Report.  Reminder not to invoke sympathy or try in any way to convince or coerce the cashier to allow any possible non-authorized foods to be purchased.  Circumstances when to leave the store immediately.  Which WIC foods to purchase, and the procedures for using an eWIC benefit. 3. Compliance Buy Process: • There will always be at least two compliance purchases made at each retailer to establish a pattern of compliance or non-compliance. These purchases can occur on the same day but ideally, are spread out when possible. • The investigator will complete and document the following during a compliance purchase: o Note the time you enter the store. o Verify self-price tags. o Select the food items to purchase and make note of their posted shelf price. o Note the general description of the cashier. o Check for the following occurrences:  Cashier providing beginning balance receipt, purchase receipt, and remaining balance receipt from the point of sale.  Charging more than the posted shelf price.  Charging for foods not received.  Providing credit or non-food items in an eWIC transaction.  Providing an unauthorized food item, including charging for food provided in excess of those allowed by the eWIC card.  Giving change or requiring cash to be paid in full or in part.  Charging investigator more for WIC-approved foods than a non-WIC customer. o The investigator will tell the cashier before the items are rung up that he/she will be using an eWIC card.  At the second compliance purchase, if possible, a different cashier should be used for checkout. o Once the purchase is complete the investigator will leave the store with all the receipts (beginning balance, confirmation, and ending balance) and the items purchased, and complete the appropriate documentation on the compliance buy report.  If a violation occurred during the first purchase, the investigator must not proceed with the second purchase. o The investigator will return the report and store receipts to the State Agency. o Finally, the investigator will donate all the food items to a food bank or similar organization.  A donation form, which is filed with the final report, will be signed by the staff at the organization acknowledging the donation. o Once the compliance investigation is completed the State Agency will send a letter to the retailer describing the results of the investigation. Follow up training and education will be

offered as needed. The retailer will be informed of possible sanctions being assigned if a pattern of violations occurred. • Outcomes of Compliance Purchases o A successful transaction is one in which no violations occur, and no adverse action is applied. o A failed transaction is one in which the retailer does commit a violation. o Two or more independently documented violations of the same type within the last 12 months constitutes a patternand that will result in sanctions being imposed. o If there is one failed and one successful transaction, an additional compliance purchase will have to be made to determine if there have been two failed or two successful transactions. o In the instance of a failed compliance purchase due to violations that are not yet sanctionable, retailers should be given at least 30 days from notification prior to an additional compliance purchase to allow for training. • Follow-up procedures if “No Adverse Action” is applied: o The State Agency will review the benefit transaction in SOAR after redemption. A case file will be completed on the investigation by the State Agency. This may include:  Any reports or complaints that were used to select the retailer for a compliance purchase; the investigation report; any receipts from the transaction; any document of prior warnings or retailer visits; the letter sent to the retailer notifying the retailer of the compliance purchases; any correspondence from the retailer regarding the case, including documentation of phone contact; any materials relating to a Administrative Review if one is requested, including the decision of the hearing office. o The retailer will be notified by mail of the results of the compliance investigation within 45 days of the initial compliance purchase. If the retailer is under further investigation a letter will not be sent. o The Local Agency will receive a copy of the letter. 4. Inventory Audit • An inventory audit is defined as the comparison of reported WIC purchases against the retailer’s inventory records for a specific period. o Inventory audits will not be announced in advance. The local agency will not be informed of inventory audits conducted in their area. • The WIC Retailer Agreement, in Section VI: Accounting, Auditing, Record Retention, Cost Principles and Access to Records, required retailers to maintain inventory records and other records related to purchases for a minimum three-year period. • Procedure o A WIC staff member or a designated representative will visit the retailer to determine the total amount of stock available. This includes what is on the shelves as well as in the storage area. This must occur on the first day of the inventory period. o On the last day of the inventory period, a WIC staff member or a designated representative will visit the retailer to calculate the total amount of stock available.

o A WIC staff member or a designated representative will visit the retailer’s offices. A request to view the invoice receipts will be made at that time. A calculation based on the beginning stock, the ending stock, and the amount of stock purchased according to the Invoice receipts will be compared to redemption records to verify the amount of stock presumed sold in WIC purchases. 5. Follow-up Actions • Follow-up Action to either compliance buys, or an inventory audit, will include: o The retailer will be notified, by certified mail, of the investigation, violations found and the subsequent consequences, if applicable. A copy will be sent to the local agency. o The retailer can appeal any sanction or disqualification. Retailers must request an Administrative Review from the Montana WIC Program. o The Montana WIC Program will notify the Regional FNS Office of any WIC retailer disqualification. If the retailer involved is part of a “chain”, the chain’s regional/district manager will be notified. o Disqualification from the Montana WIC Program may result in disqualification from SNAP.

Section III: State Agency Procedure Manual I. State Vendor and Farmer Management H. Federal Violations and Sanctions Purpose Standardized Federal violations and sanctions ensure program integrity. Policy The Montana WIC Program shall determine the type and level of Federal sanction to be applied against retailers based upon the severity, nature, and pattern of the violation. 1. Notification of Violation • If a retailer has committed a violation that requires a pattern of occurrences to impose a sanction, the Montana WIC Program will notify the retailer of the initial violation in writing prior to documentation of another violation. • Notification is not required: o For WIC retailer disqualifications or Civil Money Penalties based on Supplemental Nutrition Assistance Program (SNAP) sanctions. o For violations that only require one incident before a sanction is imposed, or, o If such notice could compromise covert investigations being conducted by the Supplemental Nutrition Assistance Program (SNAP), the USDA Office of the Inspector General, the State Police, or an ongoing WIC investigation or other authorities.  Reason for not informing will be documented in the retailer’s chart. 2. Establishing a Pattern of Violations • Montana WIC Program sanctions require documentation of a pattern of the same type of violation. A pattern of violations can be based on at least two (2) independent documented violations during any compliance investigation, at least three (3) documented independent violations obtained through objective data or other non-compliance purchase investigations or one (1) inventory audit where discrepancies were found. o When multiple violations are detected during a single investigation, the disqualification period will be based on the most serious violation. o The Montana WIC Program may not accept voluntary withdrawal of a retailer from the WIC Program as an alternative to disqualification. o Any retailer who commits fraud or abuse of the Program is liable to prosecution under applicable Federal, State, or local laws. Those who have willfully misapplied, stolen or fraudulently obtained program funds will be subject to a fine of not more than $25,000 or imprisonment for not more than five (5) years or both if the value of the funds is $100 or more. If the value is less than $100, the penalties are a fine of not more than $1,000 or imprisonment for not more than one (1) year or both. (7 CFR §246.12 (h) (3) (xxi)) 3. Retailer Noncompliance • Montana WIC may initiate administrative action to disqualify or assess a fine against a retailer for non-compliance based on one incident of a violation or a pattern of violations. An incident is defined as one isolated event at a single point in time or any single occurrence of a violation. A pattern is defined as two or more incidences of a violation. • Mandatory sanctions are federal penalties and shall constitute grounds for disqualification from

the WIC Program for a minimum of one (1) year and up to permanent disqualification. 4. Mandatory Violations and Sanctions • Class A and B violations are subject to mandatory federal sanctions and shall constitute grounds for disqualification from the WIC Program for a minimum of one (1) year and up to permanent disqualification. o Class A Violations: These violations require one incident and are subject to mandatory federal sanctions as defined in 7 CRF 246.12 and shall constitute grounds for disqualification from the WIC Program for a minimum of three (3) years and up to permanent disqualification. Class A violations include:  A conviction for trafficking (buying or selling WIC food benefits), conviction of selling firearms, ammunition, explosives, or controlled substances in exchange for WIC food benefits – Length of disqualification – Permanent.  The WIC Program reserves the right to impose a Civil Money Penalty (CMP) in lieu of permanent disqualification, particularly in cases of a participant access determination.  One incident of trafficking (buying or selling WIC food benefits), selling firearms, ammunition, explosives, or controlled substances in exchange for WIC food benefits – Length of disqualification – Six (6) years.  One occurrence of the sale of alcohol, alcoholic beverages, or tobacco products in exchange for WIC benefits – Length of disqualification – Three (3) years. o Class B Violations These violations require a pattern to be documented before a sanction can be imposed. Unless otherwise noted, “pattern” is defined as two or more of the same Class B violations which occur during the retailer’s contract period. For a single Class B violation, the retailer may be given written notice of the violation. When written notice is given the retailer must establish a corrective action plan that includes the retailer’s attendance at a mandatory training to be completed within sixty (60) days of the notice. At the end of the disqualification period a new application for authorization may be submitted. In all cases the retailer’s new application will be subject to the Montana WIC Program’s retailer selection criteria in effect at that time. Class B violations include:  Claiming reimbursement for the sale of any WIC item that exceeds the store’s documented inventory of that food item for a specific period – Length of disqualification – 3 years.  Charging WIC participants more for WIC approved foods than non-WIC customers or charging more than the posted shelf price (overcharges) – Length of Disqualification – 3 years.  Receiving, transacting, and/or redeeming WIC food benefits outside of authorized channels, including the use of an unauthorized retailer and/or an unauthorized person – Length of disqualification – 3 years.  Charging the WIC Program for WIC foods not received by the WIC participant – Length of disqualification – 3 years.  Providing credit or non-food items, other than alcohol, alcoholic beverages, tobacco products, cash, firearms, ammunition, explosives, or controlled substances, in exchange for WIC food benefits – Length of disqualification – 3 years.  Providing unauthorized food items in exchange for WIC food benefits, including charging

for supplemental food provided more than items available on the benefit – Length of disqualification – 1 year. 5. Other Disqualifications • The Montana WIC Program shall disqualify a retailer that has been disqualified from SNAP. The WIC disqualification will be for the same length of time as the SNAP disqualification, and the WIC disqualification may begin later than the SNAP disqualification. This disqualification is not subject to administrative or judicial review un the WIC Program. • The Montana WIC Program shall disqualify a retailer who has been assessed a Civil Money Penalty (CMP) for hardship in SNAP under 7 CFR 278.6. The length of disqualification will correspond to the period for which the retailer would otherwise have been disqualified in SNAP. o The WIC Program will include notification that it will take such disqualification action in its sanction schedule, and; o Conduct a participant access determination. If the WIC Program determines that inadequate participant access would result from the disqualification, then neither a disqualification nor a civil money penalty in lieu of disqualification may be imposed. 6. Prosecution and Fines A retailer committing fraud or abuse of the WIC Program is liable to prosecution under applicable federal, state, or local laws. • Appeals & Notice o A retailer may appeal a denial of authorization. The retailer may also appeal action taken during a contract where the retailer is disqualified, or any other adverse action is taken. The exception is that the retailer cannot appeal the expiration of the contract and the Montana WIC Program’s participant access determination for a mandatory or Montana WIC Program violation. • Civil Money Penalty (CMP) In Lieu of Disqualification o The Montana WIC Program shall consider Civil Money Penalties (CMP) in lieu of disqualification for mandatory sanctions if the retailer was authorized under a participant access determination. o If a vendor is assessed a second mandatory sanction, the WIC Program must double the second sanction. CMP may only be doubled up to the limits allowed under 7 CFR 246.12(I)(1)(x)(C). o If a vendor is assessed a third mandatory sanction, the WIC Program must double the third sanction. No CMP may be issued in lieu of disqualification. • Calculation of a Civil Money Penalty o The CMP shall not exceed the maximum amount specified in 7 CFR 3.91(b)(3). Further information on calculating CMPs and using these maximums can be found in federal WIC regulations at 7 CFR 246.12(l)(1)(x). • Failure to pay Fine/Civil Money Penalty o If a retailer does not pay or partially pays a fine and/or CMP within the specified time frames, the Montana WIC Program will disqualify the retailer for the length of the disqualification corresponding to the original violation.

Section III: State Agency Procedure Manual I. State Vendor and Farmer Management H. State Program Violations Purpose Standardized state program violations and repercussions ensure program integrity. Policy State program violations include incidences of non-compliance of vendor selection criteria and/or vendor agreement provision. This policy defines those violations, and their corresponding corrective action schedules. ____________________________________________________________________________________ 1. Retailer Noncompliance • All selection criteria and vendor agreement provisions must be maintained throughout the term of the agreement and the Montana WIC Program reserves the right to terminate vendor agreements for cause. This is determined in a standardized manner applied to all vendors based on the violations outlined in this policy. • The repercussions for the violations in this policy are defined by the occurrences of the violations. o An occurrence of a violation is an isolated incident that occurs at one point in time. 2. Class 1 State Program Violations • The following violations are considered Class 1: o Failure to maintain minimum stock of WIC foods as identified outside of a routine monitoring visit. o Purchasing infant formula from a source not on the “Infant Formula Wholesalers/Distributors/Retailers/Manufacturers” list. o Participating in a conflict of interest between WIC staff, either state or local, and vendor staff. o Failure to extend the same courtesies to WIC customers as all other customers. • Class 1 violations will result in the following corrective action schedule: o First occurrence – The retailer will receive a written or verbal notification of the violation and complete a Corrective Action Plan (CAP) to address the violation. o Second occurrence of the same violation within one calendar year of the first - The retailer must attend mandatory training with WIC staff. o Third occurrence of the same violation within one calendar year of the first - The retailer’s agreement may be terminated at the discretion of the MT WIC Program. If there is a participant access issue the vendor may be required to complete an additional CAP within (30) days of the notice of a fourth occurrence in lieu of

termination. If the vendor agreement is terminated the MT WIC program will specify the time- period for termination at its discretion, up to 12 months. 3. Class 2 Program Violations • The following violations are considered Class 2: o Failure to give access to the WIC program requested documentation for auditing purposes. o Failure to allow in-store visits by WIC representatives. o Intentional failure to provide WIC customers with the same promotions as all other customers. • Class 2 violations will result in the following corrective action schedule: o First occurrence – The retailer will receive a written and verbal notification of the violation must attend mandatory training with WIC staff. o Second occurrence of the same violation within one calendar year of the first – The retailer must complete a CAP within thirty (30) days of the notice. o Third occurrence of the same violation within the same calendar year of the first – The retailer’s agreement may be terminated at the discretion of the MT WIC Program. If there is a participant access determination the vendor may be required to complete an additional CAP and attend training within (30) days of the notice in lieu of termination. If the vendor agreement is terminated the MT WIC program will specify the time-period for termination at its discretion, up to 12 months.