655.1 Policy 655 Homeless Applicants December 2, 2019

POLICY Applicants experiencing homelessness shall be considered eligible for the WIC program and offered equitable access to WIC services. Local agencies shall conduct outreach activities to facilities serving participants experiencing homelessness. Local agencies will ensure that WIC services benefit the participant and not the homeless facility. PURPOSE To ensure WIC services reach a population in critical need. To implement federal regulations ensuring that WIC services and food benefits are used only by WIC participants. RELEVANT REGULATIONS 7 CFR §246.7 ¶(e)(2)(iv) Nutritional risk criteria 7 CFR §246.7 ¶(n) Certification of persons and food benefits are used by the WIC participant OREGON WIC PPM REFERENCES  510 – eWIC Cardholder Requirements  470 – Local Program Outreach  610 – Required Proofs – Identity, Residency, Income  616 – Unavailable Proofs  650 – WIC Transfers/VOC and WIC Overseas Program  769 – Assigning WIC Food Packages APPENDICES Page 655.7 Appendix A Sample Cover Memo from Local WIC Program to Homeless

Facility Page 655.8 Appendix B Sample Letter of Agreement/Memorandum of Understanding between Homeless Facility and Local WIC Program DEFINITIONS Family: A group of related or nonrelated individuals who are living together as one economic unit. Residents of a homeless facility or an institution shall not be considered members of a single family.

Homeless Applicants, Continued 655.2 Individual experiencing homelessness: A person who lacks a fixed and regular nighttime residence, or whose primary nighttime residence is one of the following: • 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 (such as cars, park benches, abandoned buildings, or campgrounds). • Long-term or extended stays in hotels or motels. • A supervised publicly or privately-operated shelter designed to provide temporary living accommodations (including a welfare hotel, a congregate shelter or a shelter for victims of domestic, interpersonal violence). • An institution that provides a temporary residence for individuals intended to be institutionalized. BACKGROUND Poverty, unemployment, and lack of affordable housing are commonly associated with homelessness. Mental health, substance use disorders, trauma and violence are often present as well. Lack of safe, affordable housing and related issues predisposes a person to inadequate nutritional patterns, higher incidence of health issues, stress and anxiety which places the individual at nutritional risk. Federal regulations require State WIC agencies to demonstrate how program benefits are offered to eligible individuals experiencing homelessness. In addition, federal regulations require local WIC programs to ensure that facilities serving the homeless meet specified criteria in order for eligible residents to receive WIC food benefits. PROCEDURE Providing WIC Services 1.0 Local agency staff shall make every effort to reduce barriers that might prevent individuals experiencing homelessness from receiving WIC program benefits. Participants unable to provide proof of income 2.0 An individual experiencing homelessness shall not be excluded from receiving WIC benefits due to the inability to provide proof of financial eligibility.

If the person is living in a shelter or institution, the “family unit” does not include other residents of the shelter. Only the participant or group of related persons shall be counted (e.g. mother, infant, child)

If an individual experiencing homelessness reports zero income or is unable to provide documentation of income, the local agency staff shall complete the “No Proof Form” (form 57-633). Refer to ♦ Policy 616 – Unavailable Proofs. Participants without a permanent address 3.0 Applicants or participants must reside within the jurisdiction of the State. Applicants and participants do not have to be U.S. citizens or permanent residents. Determining proof of residency can be challenging when the applicant does not have a permanent residence or is living with others. Refer to ♦ Policy 610 – Required Proofs- Identity, Residency, Income for guidance on what counts as proof of residency.

Homeless Applicants, Continued 655.3

To assess whether an applicant is experiencing homelessness when living with others, ask open-ended questions in a participant centered manner to get insight on the applicant’s living conditions. For example: 3.1.1. Mom and baby have been staying with a friend for 3 months but are sleeping on the living room floor and are managing their own food and resources. The friend is losing patience and has asked mom and baby to leave. In this example mom and baby are experiencing homelessness. 3.1.2. Mom and baby are living with a friend. They have their own room. Mom contributes to the household income with a part time job. They split grocery costs, share child care, utilities, etc. This is a stable arrangement. This mom and baby are not experiencing homelessness.

If an individual experiencing homelessness cannot provide proof of residency the local agency staff shall provide the “No Proof Form” (form 57-633). Refer to ♦ Policy 616 – Unavailable Proofs.

An address is needed when issuing an eWIC card. Individuals experiencing homelessness should be marked as homeless in the data system. They can provide an address they can easily remember (e.g. childhood home, friend’s address), the address of the homeless facility, or they can use the address of the local WIC program. Refer to ♦ Policy 510 – eWIC Cardholder Requirements. 3.3.1. Exception: Do not use the address for a shelter or facility for participants experiencing interpersonal violence when the facility requires confidentiality. Verification of Certification (VOC) 4.0 Local agency staff must provide a Verification of Certification (VOC) form when the applicant states they are experiencing homelessness. This will facilitate an individual experiencing homelessness staying on the WIC program when they relocate. Refer to ♦ Policy 650 – WIC Transfers/VOC and WIC Overseas Program. Determining if a facility meets requirements for issuance of WIC food benefits 5.0 In order to provide WIC food benefits to a participant(s) living in a homeless shelter, domestic violence shelter, facility or institution, local agency staff shall contact the organization to find out if the facility meets the following requirements: • WIC program services only benefit the WIC participant, not the facility (WIC participants will be able to store and prepare WIC foods for their own consumption); • The facility does not accrue financial or in-kind benefit from the person’s WIC participation (e.g. the facility cannot reduce expenses for food or other items because a resident receives WIC foods or services); • WIC foods will not be used in communal feeding; and • The facility will not restrict the participant’s use of WIC services, for example, attending classes or shopping at WIC authorized vendors.

Homeless Applicants, Continued 655.4 Record keeping 6.0 The Local WIC agency must ensure compliance with the requirements by requesting the facility complete a Letter of Agreement or Memorandum of Understanding (MOU) including requirements listed in 5.0. Refer to Appendix A and Appendix B for sample forms. 6.1.1. Assess the facility every three years. 6.1.2. Keep the completed form on file for 3 years. Facilities meeting requirements 7.0 Future eligible WIC applicants from that facility should be certified for the full period for which they are eligible.

The facility does not need to be contacted for each new applicant from the facility.

Contact the facility every three years to assure they are still in compliance with the agreed-upon conditions. The facility should also be contacted if the WIC program staff receives information that the facility is no longer compliant with the conditions, for example, from a new WIC applicant.

If participant reports residing in a facility for which an agreement is not on file with the local WIC agency, the local agency shall contact the facility by phone to establish that the facility complies with the conditions of the agreement. The local agency will follow-up by sending the facility a Letter of Agreement or MOU to complete and return to the local WIC agency. Facilities not meeting the requirements 8.0 If it is determined that a facility does not comply with the requirements:

Continue WIC benefits and services to any residents of that shelter who are already certified for WIC for that certification period.

Inform those participants that their WIC food benefits will cease after their current certification period and refer them to other homeless facilities where they could continue to receive WIC food benefits. Exceptions

Recertify residents of the non-compliant shelter only for nutrition or breastfeeding education services but not for WIC food benefits, with these exceptions: 8.3.1. Infants may continue to receive infant foods and infant formula. 8.3.2. WIC participants may select a designated homeless facility employee to be the second card holder to shop for the infant formula and infant foods. It’s the WIC participant’s responsibility to inform the second card holder how to use the eWIC card.

Do not issue WIC food benefits to future eligible applicants who are residents of the non-compliant facility. EXAMPLE 1: Sarah Montgomery has been screened and found eligible for WIC services. Ms. Montgomery is homeless and gives her address as the Right Path shelter. WIC staff has no record of whether Right Path complies

Homeless Applicants, Continued 655.5 with WIC guidelines. Ms. Montgomery is certified for the full period for which she is eligible. The WIC coordinator calls and speaks to the manager of the Right Path shelter. She determines that Right Path does not meet WIC criteria, as residents eat meals prepared by church volunteers and there is no provision for residents to store or eat food individually. The WIC coordinator documents the conversation, including the date and name of the manager. Ms. Montgomery may remain on the WIC program, receiving food and other services, for her full certification period. WIC staff determines that another facility in their county, Womenspace shelter, allows residents to store and prepare food independently. Any future WIC applicants who are staying at the Right Path shelter must be told they are not eligible for WIC food benefits but would be if they moved to the Womenspace shelter.

EXAMPLE 2: Mona Smith has been screened and found eligible for WIC services. Mona is homeless and is staying at the Guiding Light shelter. WIC staff has determined that the Guiding Light Shelter does not allow residents to store and cook food independently, so this shelter is not in compliance with federal guidelines for participants to receive WIC food benefits. Ms. Smith can benefit from WIC nutrition education and referrals but cannot receive WIC foods. To receive WIC foods, she would need to find a shelter that meets the requirements by contacting the WIC clinic for assistance locating an eligible facility. If she had an infant, that infant, however could receive infant foods and infant formula through WIC. Institutions or facilities that provide meals 9.0 WIC food benefits are not to be issued to a participant living in a facility or institution that provides all the meals for the individual. Examples include: substance abuse treatment centers, jail, correctional facilities, mental institutions, long-term care facilities.

A participant living in a facility or institution that provides meals can receive other program benefits including nutrition focused counseling, health assessments, referrals, etc.

The participant is eligible to receive WIC foods when released from the facility or institution when in a current certification period. Food Benefit Issuance 10.0 Provide the maximum food package that will be safe and sanitary for the participant’s living situation. Refer to ♦ Policy 769 – Assigning WIC Food Packages for guidance on food packages specific to living situations such as, limited storage, no refrigeration, or homelessness. To determine the best food package to address a participant’s living situation, explore topics such as food storage, transportation, ability to access grocery stores and use of specific food items.

Homeless Applicants, Continued 655.6 Counsel participants on their WIC food benefits and services when living in homeless facilities that meets the requirements: 10.1.1. If the person is living in a shelter, the WIC foods must be kept separate from the facility’s general food supply and be used by the participant only. 10.1.2. WIC foods cannot be used in community meals. 10.1.3. The homeless facility where they reside cannot prevent the WIC participants from receiving WIC foods and nutrition education. Outreach to facilities serving individuals experiencing homelessness 11.0 Local agencies shall conduct outreach activities to notify homeless individuals of the availability of WIC services. Refer to ♦ Policy 470 – Local Program Outreach. Targeted outreach activities to reach individuals experiencing homelessness might include: 11.1.1. Identify and target suitable homeless shelters and feeding centers in your service area for outreach activities. 11.1.2. Set up an appointment with the facility to meet, promote WIC services, learn about their organizational structure and provide a Letter of Agreement or MOU. 11.1.3. Explore opportunities for staff in-services to explore barriers to services and opportunities for referrals to WIC. 11.1.4. Enter the facilities into your referral data base in the WIC data system.

POLICY HISTORY Date * Major revision, Minor revision 9/15/2016 Revision 12/2/2019 Major revision

The date located at the top of the policy is the implementation date unless an “effective date” is noted on the policy. Policies will become compliance findings 6 months from the implementation date. Release notes can be found in the corresponding document on the Policy and Procedure Manual page. *Major Revisions: Significant content changes made to policy. Minor Revisions: Minor edits, grammatical updates, clarifications, and/or formatting changes have occurred. Date of Origin: Date policy was initially released If you need this in large print or an alternate format, please call 971-673-0040. This institution is an equal opportunity provider.

Homeless Applicants, Continued 655.7 APPENDIX A Sample Cover Memo from Local WIC Program to Homeless Facility

DATE:

TO:

FACILITY NAME

FROM:

LOCAL WIC PROGRAM/WIC COORDINATOR

ADDRESS/PHONE #

RE: WIC Services for your Residents

The Women, Infants, and Children Program (WIC) provides nutrition education, breastfeeding support, referrals and supplemental foods to lower-income mothers and children. Those on WIC can get foods such as eggs, fruit, vegetables, milk, cereal, cheese and more, which help these participants meet special dietary needs.

Residents of your facility/ shelter, who are pregnant or breastfeeding women, or children up to five years of age, may be eligible for WIC services.

Federal regulations require that WIC services benefit the WIC participant, not the facility that is housing them. This means:

• WIC participants will be able to store and prepare WIC foods for their own consumption. • WIC foods will not be used in communal feeding. • No restrictions will be placed on the WIC participant's use of WIC services. (WIC participants will be able to attend WIC nutrition education classes and one-on-one counseling sessions, and shop, or have an authorized signer shop, for them at WIC-authorized stores.)

Please complete and return the enclosed form to indicate if residents of your shelter may receive WIC foods. Please call us if you have any questions or need more information.

We want WIC services to reach those who need it and hope to work with you and your residents in the future. Enclosed is general information about WIC. Please refer any of your residents that may be eligible.

Thank you for your time and attention.

ENC.: WIC annual report, WIC outreach brochures

Homeless Applicants, Continued 655.8 APPENDIX B Sample Letter of Agreement/Memorandum of Understanding (MOU) between Homeless Facility and Local WIC Program Memorandum of Understanding (MOU)

For WIC Participants between the County WIC Program and the XXX Shelter or Homeless Facility

DATE:

TO:

LOCAL WIC CLINIC

FROM: FACILITY NAME

RE: WIC Services for the Residents of our Facility – Memorandum of Understanding

For residents in homeless facilities to participate in WIC, federal regulations require that WIC program services benefit the WIC participant, not the shelter. This means:

• WIC participants will be able to store and prepare WIC foods for their own consumption. • WIC foods will not be used in communal feeding. • No restrictions will be placed on the WIC participant's use of WIC services. (For example, WIC participants will be able to attend nutrition education and breastfeeding counseling sessions/classes. WIC participants will also be able to shop at WIC-authorized stores or choose an authorized signer to shop for them.)

Please check the box that applies, sign below and return this form to the county WIC program: □ Yes, the above conditions apply for residents of our facility. □ No, the above conditions do not apply for residents of our facility. We understand that this means our residents will be able to receive nutrition education and breastfeeding support services, but not be able to receive WIC food benefits.

SIGNATURE OF HOMELESS FACILITY EMPLOYEE AND JOB TITLE

FACILITY NAME AND ADDRESS

PLEASE RETURN THIS FORM TO YOUR LOCAL WIC PROGRAM. THIS FORM WILL BE UPDATED BY THE WIC AGENCY EVERY THREE YEARS.