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2 of 4 West Virginia WIC Policy & Procedure 8.03 8.03 Participant Access Assessment Effective Date: 4/7/2021

2. The applicant’s original application and related attachments shall be evaluated under the inadequate participant access criteria stated in Section C when determining if denial of authorization for any of the selection criteria (other than minimum stock requirements) would result in inadequate participant access.

3. Any determination finding inadequate participant access shall be made in consultation with the applicable local agency unless inadequate participant access is a result of the geographic location of the next nearest authorized retail store location exceeding three (3) miles driving distance.

To augment the PAA process, it is vital to obtain timely feedback from the local agency whom may have special knowledge about local conditions, such as physical barriers based on their familiarity of the community and on-going association with eligible participants. However, feedback such as participants’ preference and convenience are not considered legitimate issues for the local agency to raise when providing their PAA response. All responses submitted should be objective statements of fact pertaining to potential participant impact.

All information provided as part of this evaluation process shall be complete and accurate. The information contained in the written assessment may be subject to further review by the State WIC Office, retail store managers, a store’s legal counsel or other personnel involved in the decision-making process, i.e., adjudication officer.

B. Completing a Participant Access Assessment

1. Prior to taking denial actions against an applicant the Vendor Operations and Training Specialist completes an Participant Access Assessment (PAA) Form (Attachment #1). Prior to taking termination or disqualification actions against an authorized retail store, the Vendor Authorization and Monitoring Specialist completes a PAA Form. Specific background information related to the affected store is sent (i.e., hard copy or email) directly to the WIC Vendor Manager. Along with the completed PAA Form, a geographic map should be included for his/her review as well as other optional attachments.

2. The State Vendor Manager or his/her designee shall review and respond within 10 business days of receipt. In the “comments” section of the PAA Form, the State Vendor Manager shall indicate in his/her completed response agreement and/or disagreement to the recommendations being made by the Vendor Operations and Training Specialist or Vendor Authorization and Monitoring Specialist.

3. The State WIC Office shall retain and maintain originals of all responses and paperwork related to assessments which will be filed in Section Two of the Vendor paper record. All documents will also be scanned into the Vendor Crossroads (XR) record on the Vendor Authorization Screen.

4. Under no circumstances should the State WIC Office or any local agency personnel inform a retailer and/or store personnel that administrative action is under consideration. All information contained in the PAA is considered confidential.