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I (A). FOOD DELIVERY

GOAL: To investigate a minimum 5% of the Program’s authorized vendors for compliance with federal regulations during the federal fiscal year.

METHODOLOGY: The compliance liaison, under the direction of the unit supervisor, manually selects vendors for investigation based upon participant and local WIC office complaints and high-risk reports generated from the Food Delivery Portal, Store Tracking and Redemption System (STARS), and/or Crossroads Management Information System. Investigation priority is determined according to the severity of the possible infractions to the program.

The State Agency (SA) will also develop policy and procedure as well as tools to institute inventory audits as a method of compliance investigations. Technical assistance will be sought from other states as recommended by the regional office through technical assistance site visits and/or review of approved procedures and tools.

EVALUATION: Regional office approval of the inventory audit policies, procedures and tools will be secured to initiate use of inventory audits for compliance investigations. The number of compliance investigation letters will be recorded to track the most common state violations or customer service issues. This information will inform quarterly newsletter items as well as state standards.

STATUS: The 5% minimum requirement will be completed by 9/30/24; 10 compliance investigations have been completed with 13 vendors and within the 4th quarter of FFY2024 all 13 investigations will be completed. The SA continues to utilize Policy 8.09 as well as the Compliance Buy Investigation Standard Operating Procedures, with revised reporting form and notification template letter. Written notification was mailed following every investigation regardless of result.

The development of 8.12 inventory audit policy, procedure and standard operating procedure were drafted and approved in January 2024. Inventory audits have begun as of May 2024 with 2 investigations. Unfortunately, vendors have not been forthcoming in producing requested records so to date no audit has been successful. Hence implementation of inventory audits is ongoing for FY 2025. Inventory audits will be utilized for all vendors designated high risk because of volume and redemption risk indicators. Compliance buys will be utilized for all vendors designated high risk for participant risk indicators and new vendors.

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