West Virginia WIC Policy & Procedure 1.10 Effective Date: 1/30/2026 1.10 Alternate Operating Procedure

POLICY:

The purpose of this policy is to provide guidance for West Virginia WIC State and Local Agencies in responding to disaster situations which may include natural, Public Health, supply chain disruptions, particularly those involving infant formula. It also outlines WIC’s role regarding coordination and planning for natural disasters.

This Alternative Operating Procedure (AOP) policy outlines the Continuity of Operations (COOP) priority for the Office of Nutrition Services (ONS), within the West Virginia Department of Health, which is to provide continued Special Supplemental Nutrition Program for Women, Infants, and Children (WIC) services and a healthy and safe environment for participants and staff in the clinics, distribution sites, authorized grocery stores, and local, regional, and state offices. The AOP policy is used as a guide to help ensure that all essential functions of ONS and its Programs will continue to be performed under all threats and conditions. ONS staff can achieve the latter while also minimizing the impact on its mission, participants, Programs, personnel, and information technology operations. Critical employees have been identified in the event of a disaster.

The ONS, in the event of an emergency or major disaster affecting large numbers of participants, will take those resources necessary to:

A. Provide for the safety of personnel and equipment; B. Secure records, equipment, materials and supplies; C. Restore WIC Program operations and delivery of service as soon as possible; D. Support the emergency procedures of the Bureau for Public Health, Center for Threat Preparedness and the West Virginia Office of Emergency Medical Services.

The extent of disaster preparation depends on the type of disaster.

E. When there is advance notice that a WIC clinic may be damaged by a flood, WIC personnel will attempt to remove vehicles, computer equipment, participant charts, medical supplies and equipment to a secure location. F. When a WIC clinic is struck by lightning which causes a fire, there is no time to make advance preparations. In this case, it is important that all people inside the building leave immediately and call the fire department.

When there is advance notice that a disaster may occur, the Local Agency Director will take immediate action upon receipt of the notice.

During a disaster, the mission of the West Virginia WIC Program remains the same:

To improve the health of women, infants and children in West Virginia by providing quality nutrition and breastfeeding counseling and education; as well as health monitoring and nutritious foods.

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This Office of Nutrition Services Alternative Operating Procedure policy will be reviewed and updated as required.

PROCEDURE:

A. Role of the USDA Food and Nutrition Service (FNS) in Disaster Response

USDA’S Food and Nutrition Service (FNS) provides food assistance to those in need in areas affected by a disaster. This Federal assistance is in addition to that provided by State and local governments.

USDA provides disaster food assistance in the following ways:

• USDA Foods are currently stored in every state and U.S. territory and may be used by state agencies or local disaster relief organizations to provide food to shelters or families/individuals who are sheltering in place. • If retail food stores are operating in the impacted area, state agencies may request to operate a Disaster Supplemental Nutrition Assistance Program (D-SNAP). • A state or U.S. territory may request additional disaster waiver flexibilities to assist existing SNAP households affected by a disaster to have their regular program benefits replaced if food purchased with benefits was destroyed. • At the request of a state or U.S. territory and in the event of a Presidential Disaster Declaration for individual assistance, FNS may approve a waiver that allows SNAP households to purchase hot, prepared foods for immediate consumption for a period of time. •In certain circumstances, FNS can also provide infant formula and food within 96 hours of a request by FEMA or a state agency. B. Role of WIC in Disaster Response

Although the WIC Program is not designed to be a disaster assistance program, and therefore is not considered a first line of defense, WIC policies are designed to allow State agencies flexibility in program design and administration to support continuation of benefits to participants during times of natural or other disasters.

1. WIC is not designed or funded to meet the basic nutritional needs of disaster victims who would not otherwise be eligible for the Program.

a. There is no legislatively mandated role for WIC in disaster relief, nor is there legislative authority for using WIC food funds for purposes other than providing allowable food benefits to categorically eligible participants. 2 of 11

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b. No additional WIC funds are designated by law for WIC disaster relief, and WIC must operate in disaster situations within its current Program context and funding. c. WIC is not to be considered a first-line defense to respond to the nutritional needs for disaster victims, including the provision of infant formula.

2. There are important ways that the State Agency and Local Agency can contribute to a disaster relief effort (See Policy and Procedure 2.22) including:

a. Continued benefit delivery to participants and outreach to potentially eligible individuals.

b. Counseling participants on food preparation and safety under disaster conditions. c. Coordinated assistance effort through continued communication with disaster relief agencies with pre-disaster planning during a disaster.

C. Disaster Coordination and Communication

1. The following designated emergency contacts within the State Agency (SA) for disasters, emergencies, public health emergencies, supplemental food recalls and other supply chain disruptions to ensure that the appropriate entities (e.g., Regional Offices, other State Agencies and Coordinating programs) are aware of the SA’s designated contacts. Area Emergency Contact Office Phone State Agency Disaster Coordination Office Director 304-352-0960 Administration/Nutrition Services Deputy Director 304-352-0967 Vendor Management Division Director 304-352-0954 Crossroads/MIS Services Division Director 304-352-0956

2. The above named individuals will be tasked with providing contact information for key SA staff on the SA’s public website and to ensure that this information is kept up to date. They will also ensure that the appropriate entities (e.g., Regional Offices, or other State agencies, coordinating Programs) are aware of the SA’s designated contact and to ensure that this information is kept up to date.

3. The State Agency Disaster Coordinator is responsible for coordinating and planning WIC disaster relief and communicating with the West Virginia Department of Public Health, West Virginia Office of Emergency Services, Center for Threat Preparedness and the FNS Regional Office. 4. The State Agency Disaster Coordinator will establish a working relationship with the State agency responsible for coordinating and planning disaster relief to do the following:

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a. Discuss ways they could contribute to a relief effort, such as sharing expertise about the nutritional needs of the WIC eligible population.

b. Learn how the State plans to provide food to the general population to determine how the WIC Program can appropriately assist the State in response to disasters or emergencies.

5. The Nutrition Services (NS) area will address the needs of participants with

documented qualifying conditions receiving Food Package III. They will provide

participants with a point of contact at their Local Clinic as well as the SA’s public

website for additional information. ONS will ensure this information is kept up to

date.

6. ONS will work with relief agencies responsible for disaster and public health emergency planning which includes the West Virginia Bureau for Public Health Continuity of Operations Plan (COOP) elements, including the Center for Threat Preparedness. The Office will coordinate with FEMA, relief organizations, State and local emergency operation centers and maintain a list of these agencies’ contacts that is kept up to date. The State Agency Disaster Coordinator will identify WIC SA staff positions for full or partial deployment if needed through the duration of the disaster.

7. ONS will notify FNS partners, State and Local Agency (LA) staff, authorized WIC vendors, WIC participants and the public informed during an emergency, food recalls or other supply chain disruption. ONS will maintain the Community Service Directory (ATT 1) and utilize active vendor listing in Crossroads to keep those entities informed during the disasters. FNS partners - FNS MARO Supplemental Nutrition Division Director, MARO Supplemental Food Programs Branch Chief and Team Leads will be notified and kept apprised of ongoing disaster related issues and/or public health emergencies. LAs through the SA will utilize Documentation of Disaster Problems and Resolutions (ATT 2), to keep FNS apprised of disaster related issues. Through the LA and SA websites, participants and the general public will be advised of program changes that affect their area. 8. This policy will be used by the State and Local Agency as a guide for the continued operations by instituting alternate procedures as necessary through the following during a disaster:

a. Certification procedures that increase flexibility in required documentation. (See Policy 2.22)

b. Food Delivery procedures that deviate from standard food packages. (See Policy 2.22) c. Notify the public of any changes in normal program operations, including alternate procedures or locations. Increase outreach to potentially eligible individuals affected by disaster d. Designate staff to work on disaster and public health emergency teams at the State, local and clinic levels 4 of 11

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e. Designate alternate means and locations for certification and benefit issuance for circumstances in which the conventional means and locations are not possible or optimal. (See Policy 2.22) f. Plan for a back-up power system in the event of a power or other technology outage, to include a plan to access program records and issue benefits.

9. The Local Agency Director will prepare and use the list of responsibilities and designated personnel on the Emergency Preparedness Meetings, Drills and Test Exercises (ATT. 3) form that was completed during a staff meeting to discuss the emergency plan as a check list for preparation.

10.The Local Agency Director will be responsible for the following:

a. Assuring that annual pre-disaster preparation is completed; b. Maintaining communication with SA, WIC personnel, the media and local sources of food assistance during the initial disaster alert/activation phase, during the disaster and during the restoration/recovery phase; and c. Assuring that pre-disaster procedures and restoration/recovery procedures following a disaster are followed and documented per policy.

D. WIC Program Management during Disaster Situations

1. Disasters may affect caseload management and could result in priority restrictions, the use of waiting lists, shifting of caseload assignments and the need to refer applicants to other sources of food assistance because of the following factors:

a. Many people may suddenly become eligible because of loss of income; and

b. Food package adjustments, such as the issuance of ready-to-feed infant formula because of unsafe drinking water, formula shortages, and increased food costs affecting the number of people that can be served.

2. The Local Agency will take reasonable measures to continue providing food benefits to WIC participants in disaster situations.

3. The Local Agency operating in a disaster situation will actively promote the WIC Program to potentially eligible individuals, while operating within its capacity to actually serve newly eligible persons.

4. Certain situations may be so devastating to WIC operations that benefits must temporarily be suspended and participants referred to other programs or congregate feeding sites.

a. The State Agency Disaster Coordinator will contact the State disaster relief agency and the FNS Regional Office for assistance and information when the Local Agency must decide whether to suspend WIC operations in a disaster area. 5 of 11

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b. Factors that determine how well a WIC clinic can operate in a disaster situation include: a. The extent of damage on the delivery infrastructure; and i. The extent of damage on the delivery infrastructure; and ii. The extent that the Local Agency has planned and prepared for disaster situations.

E. Continuation of Benefits

To meet requirement or implement waivers the SA must first determine if the disaster meets one of the following criteria:

1. A presidentially declared major disaster as defined under Section 102 of the Robert T. Stafford Disaster Relief and Emergency Assistance Act (Stafford Act, 42 U.S.C. 5121 et seq.)

2. A presidentially declared emergency as defined under the Stafford Act 3. A public health emergency declared by the Secretary of Health and Human Services under Section 319 of the Public Health Service Act (42 U.S.C. 247d) 4. A renewal of such a public health emergency 5. A supply chain disruption as declared by the Secretary of Agriculture.

In conjunction with the State’s Office of Threat Preparedness, if SA determines one of these events exist, the SA will request a waiver to continue WIC services.

Waivers may be requested to address:

1. Physical presence for participants such a remote/virtual certification appointment 2. Separation of duties 3. Vendor and local agency monitoring Alternate operating procedures are available:

1. Certification/serving applicants and participants from an alternate WIC clinic and providing nutrition assessment and referral to other organizations 2. Set up mobile or satellite clinic to certify/serve applicants and participants and provide nutrition assessment and referral to other organizations 3. Allowing temporary certifications for applicants who are missing only one proof 4. Collection of anthropometric and bloodwork data for participants through alternate means such as the West Virginia Health Information Network 5. The collection of eligibility documentation (secure website upload, mobile device screen share, mail, secure email and video conference) 6. The collection of signatures on required documents 7. Replacement of EBT cards and destroyed supplemental foods, See WV Policy & Procedures 1.10.G.2b & 3.07.A 8. Mailing of EBT Cards, See WV Policy and Procedure 2.22E F. Certification Procedures during Disaster Situations 6 of 11

West Virginia WIC Policy & Procedure 1.10 Effective Date: 1/30/2026 1.10 Alternate Operating Procedure

The SA and LA will update their public web pages/social media accounts with

instructions for obtaining an up-to-date VOC and to notify neighboring State agencies of where a VOC may be obtained by displaced participants. This policy should help to expedite the certification process and ease transition to another SA.

1. Verification of Certification (VOC)

a.To expedite the certification process, the WIC clinic can provide Verification of Certification (VOC) to WIC participants when a disaster-related evacuation is anticipated. b.If a VOC has not been issued, participants in disaster-prone areas can be reminded during their certification visits that it is a good practice to prepare a disaster folder that contains their WIC certification documentation and plan on taking these materials with them if they are evacuated.

2. Income eligibility determination may deviate from the usual WIC Program operation in disaster situations.

a. During subsequent certification, participants who express that their income documentation was lost because of a disaster will be considered as income eligible. b. It must take place within a reasonable time period (approximately 1 month) following a disaster during which they have not had time to acquire documentation. c. The documentation will be verbally verified as similar to that documented during the previous certification. d. A note will be placed in the Income Overview Comments area in the Crossroads Income Information with the date and the statement: “Income Documentation Lost in Disaster.” e. An applicant who has a loss of income because their place of employment was destroyed and is likely to be out of work for an extended period will have income assessed based on the previous month. f. An applicant who has a temporary loss of income because of a business that sustained some damage, or a temporary loss of utilities, will have income calculated on a twelve (12) month basis.

3. While temporary shelters and tent cities in which disaster victims may stay meet the definition of a “homeless facility”, residence in such facilities does not automatically make such persons eligible for WIC. Homeless applicants must qualify through the certification process to receive WIC benefits.

4.During disasters, WIC Program employees who are also WIC participants or caretakers will not be responsible for issuing eWIC benefits/cards to themselves or members of their immediate family or conducting any aspect of the eligibility process for themselves or members of their immediate family, including issuing of VOC cards, taking anthropometric measures, and certifying the eligibility of such persons. 7 of 11

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G. Benefit Issuance and Redemption

The EBT system ensures robust telecommunications redundancy by utilizing commercial networks and available commercial POS terminals, or FIS-installed WIC-only stand-beside hardware, for benefit redemption. To enhance system reliability, the system includes backup host processing capabilities that conform to federal regulations, national standards, and specified WIC State Office performance standards. These measures ensure continuous service availability and data integrity, even in the event of network or system failures.

1. WIC participants may require a change in food package during a disaster. (See Policy 1.10.I.A)

2. EBT Card Replacement

a. EBT card replacement and benefit transfer will be completed on a daily basis as ONS is made aware. If needed, these replacements can be completed from an alternate location. b. In areas where mail could be unreliable in a disaster or emergency, they could be picked up at the clinic. c. If an emergency clinic is in place, an EBT card could be allocated to the client and later linked to the EBT account once the staff is connected to Crossroads. d. The WIC Program will not replace food lost in a mass disaster where community emergency feeding services are provided. WIC personnel will be aware of locations of emergency feeding services and sources of clean water to be able to refer those who contact WIC for this type of assistance. e. In the case of a natural disaster affecting large numbers of people in a regional or State nature where emergency declarations initiate action by Federal and State public and private disaster assistance providers, participants are not required to provide proof of disaster for food benefit replacement. f. The State Agency will provide guidance on the replacement of benefits based on the situation. The state agency will ensure they have enough funds before replacing lost EBT purchased supplemental foods. If the state agency does not have the funds, they will contact FNS for assistance.

H. Vendor Management

1. Alternative Procedures for Vendor Monitoring and Compliance Investigations

During a declared disaster affecting food supply chains or distribution networks, the State Agency activates its disaster recovery plan, which includes provisions for adjusting authorization requirements for new vendor applicants and authorized vendors. This adjustment allows expedited processing of new vendor applications and streamlines the 8 of 11

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renewal process for existing vendors to ensure continued access to supplemental foods by Women, Infants, and Children (WIC) program participants.

In this scenario, the State Agency may temporarily waive certain documentation or procedural requirements, prioritize essential inspections, or utilize electronic submission methods to facilitate swift authorization adjustments. These measures aim to maintain a robust vendor network capable of meeting increased demand during the disaster while adhering to program integrity and participant access standards.

2. Vendor Minimum Stocking Requirements (MSR) for Continuous WIC Food Distribution

To ensure uninterrupted distribution of supplemental foods to Women, Infants, and Children (WIC) program participants during disasters, this policy outlines procedures for adjusting vendor Minimum Stocking Requirements (MSR). The State Agency will assess and communicate MSR adjustments promptly to vendors, ensuring adequate food supply in times of crisis. The State Agency will make necessary and temporary NTE adjustments if and as appropriate during disaster situations.

a. Responsibilities: • The State Agency monitors and assesses food supply disruptions. • Establishes and communicates adjusted MSR procedures to vendors. b. Procedure: • Activate the disaster recovery plan upon disaster declaration. • Assess disaster impact on food availability and adjust MSR accordingly. • Communicate adjusted MSR requirements promptly to vendors. • Vendors implement adjustments and provide inventory updates. c. Monitoring and Evaluation: • Monitor effectiveness of adjusted MSR during disaster recovery. • Conduct regular evaluations for continuous improvement. d. Review and Revision: • Annually review and update policy as necessary.

3. Adjusting Vendor Authorization Requirements During Emergencies

a. The State Agency will implement alternative procedures to meet annual vendor routine monitoring and compliance investigation requirements under 7 CFR 246.4(a)(14)(iv). These measures aim to maintain program integrity and ensure continued access to supplemental foods for WIC program participants. • Remote Monitoring: Use electronic methods for vendor compliance monitoring. • Prioritized Investigations: Focus on critical vendors for food distribution. • Flexible Documentation: Adjust documentation requirements temporarily for quicker compliance assessments. • Communication and Coordination: Maintain regular communication with local agencies and vendors about adjusted procedures. 9 of 11

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• Monitoring and Evaluation: Assess effectiveness of alternative procedures during disaster recovery and conduct post-disaster evaluations. • Review and Revision: Annual review and update of policies to align with regulatory changes and best practices.

I. Nutrition Services

A. Food Delivery Procedures

1.Establish a working relationship with the State's emergency management agency and other relevant organizations (e.g., FEMA, American Red Cross). The WIC Program will not replace food lost in a mass disaster where community emergency feeding services are provided. WIC personnel will be aware of locations of emergency feeding services and sources of clean water to be able to refer those who contact WIC for this type of assistance. In the case of a natural disaster affecting large numbers of people in a region or State nature where emergency declarations initiate action by Federal and State public and private disaster assistance providers, participants are not required to provide proof of disaster for food benefit replacement.

a. The State Agency will provide guidance on the replacement of benefits based on the situation. b. WIC participants may require a change in food package during a disaster or supply chain disruption. • Adjust food packages and authorized food lists to accommodate participants with limited access to food storage or preparation facilities. • Make food package substitution adjustments based on the availability of options due to disaster or supply chain disruption c. Ready-to-feed infant formula may be issued when water sources are not safe. d. Formula in supply at the WIC clinic may be distributed to WIC participants, as necessary. i. Develop a schedule for food distribution to minimize congestion and ensure orderly access. e. There are no exemptions or exceptions allowed when medical documentation is required for the issuance of certain supplemental foods, including exempt infant formulas and WIC-eligible nutritionals during disasters. Staff can secure medical documentation by phone with hard copy documentation within a two week time period. Refer to WV Policy 4.09.F.5. f. A homeless food package may be issued to WIC participants with no storage and/or electricity. g. WIC personnel will provide nutrition counseling and handouts about safety when cooking, eating and drinking following a disaster, as necessary. 10 of 11

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4. Maintain up-to-date contact information for key staff members and partners.

B. Special Formulas

1. Strengthen partnerships with healthcare providers and hospitals to facilitate rapid collection of medical documentation needed to issue special formulas. 2. Special formula will be provided by the State contracted distribution center. The distribution center will ship requested special formulas to either the Local Agency clinic or the participant’s home considering which one is more appropriate.

C. Breastfeeding Support for Participants

1. Ensure trained Breastfeeding Peer Counselors (BFPCs) can provide support and assistance during emergencies. Peer counselor staff will educate breastfeeding participants on the importance of safe and adequate water consumption to maintain milk supply. 2. Utilize a free 24/7 lactation hotline service to provide remote/virtual breastfeeding support as able. 3. Distribute breastfeeding supplies, such as breast pumps and nursing pads, through WIC clinics and emergency distribution points. 4. Deploy breastfeeding peer counselors to emergency shelters and community centers to provide in-person breastfeeding support.

J. Outreach Procedures during Disaster Situations

The Local Agency operating in a disaster situation will increase outreach efforts to actively promote the WIC Program to potentially eligible individuals affected by disaster, while operating within its capacity to actually serve newly eligible persons.

REFERENCES:

1. SFP 93-012, WIC Income Eligibility and Natural Disasters 2. SFP 95-067, WIC Disaster Policy and Coordination 3. SFP 96-035, Revision of WIC Disaster Policy 4. SFP 96-042, Addition of Cross Reference to SFP 96-035 5. FNS WIC Policy Memorandum 2024-3 6. USDA, FNS Guide to Coordinating Special Supplemental Nutrition Program for Women, Infants and Children (WIC) Services when Regular Operations are Disrupted

ATTACHMENTS:

1. Community Services Directory 2. Documentation of Disaster Problems and Resolutions 3. Emergency Preparedness Meetings, Drills and Test Exercises 11 of 11