A. Purpose

 The purpose of the Retailer Manual is to provide information to retailers who are authorized to accept WIC. To be authorized to accept WIC cards, a retailer must have a signed agreement with the Missouri WIC program. A retailer may begin to accept WIC cards only after the application process has been completed and the WIC Retailer Agreement is fully executed. Agreements must be renewed before the end of the three-year agreement cycle. 

B. What is WIC? 

WIC is a nutrition program for women, infants and children. The United States Congress established WIC in 1973 in recognition of the need for adequate nutrition during pregnancy and early childhood, especially among low-income families. The Missouri WIC program provides nutrition education, breastfeeding support, supplemental foods and referrals for health services. 

C. Who is eligible for WIC? 

WIC services are available to women who are pregnant or who have recently had a baby, infants and children up to their fifth birthday. Participants must meet eligibility criteria (less than 185 percent of the federal poverty guidelines), be a Missouri resident and have a nutritional need. 

D. How is WIC funded? 

The Missouri WIC program is funded by the United States Department of Agriculture through the Missouri Department of Health and Senior Services, Bureau of WIC and Nutrition Services.

E. WIC supplies and resources 

The Missouri WIC program provides WIC-approved decals, signage and resources to retailers. To order supplies, please complete the Missouri WIC Retailer Order Form. The resources available to order are:

Door decals	A current WIC authorization sign must be posted at each customer entry door.
WIC-approved shelf tags	WIC-approved food items must be identified with a “WIC-approved” tag on the shelf. The only exception is the fresh produce section, which has differing track sizes and food items stocked in bins, which makes posting shelf tags difficult.
Missouri WIC Cards Accepted at this Register Sign	This sign should be posted only if there are designated registers that accept WIC. This sign is not required if all registers accept WIC.
WIC Retailer Manual	The WIC Retailer Manual provides information on how authorized WIC retailers must operate.
Retailer Register Guide	This guide provides helpful tips on processing WIC transactions.
WIC-Approved Food List	This is a supplemental visual aid for the approved foods list. A current brochure or list should be kept at each register. Approved products in the brochures are subject to change.

A. The application 

Contact the Missouri WIC program at 573-751-6204 if you have any questions about becoming an authorized WIC retailer. The Missouri WIC Retailer Authorization application can be found on the WIC retailer application webpage or by contacting the Missouri WIC program at 573-751-6204 or MOWICVendorGroup@health.mo.gov. 

To become an authorized WIC retailer, a retailer must complete an application process, meet the selection criteria and receive confirmation of authorization. Applicants must complete and submit all required application forms to the Missouri WIC program. All information must be complete. Incomplete or unsigned documents will not be accepted. 

Please ensure required signatures are obtained on all forms and mail or email the completed application and forms to: 

WIC and Nutrition Services 
Attention: WIC Agreement and Training Coordinator 
P.O. Box 570 
Jefferson City, MO, 65102-0570 

Email: MOWICVendorGroup@health.mo.gov 

Refer to WIC retailer policies in section 2.0 Retailer Contracting for further information. 

B. Steps in the approval process 

1. Complete the WIC Retailer Application, Missouri WIC Retailer Price List and WIC Retailer Communication Form. 

a. Submit a completed application for each store to become authorized, along with the supporting documentation. Application review may take up to 60 days for approval. 

2. Submit a sanitation report completed within one year of the submission date. 

a. A sanitation report must be submitted along with the application. The report can be completed within one year of the application's submission date. 

3. Submit work history to identify any previous grocery experience. 

a. Provide a resume or any documentation that outlines work history with grocery experience. 

4. Pass a pre-agreement visit conducted by the Missouri WIC program. 

a. If the application is complete and indicates the retailer would qualify, the Missouri WIC program will conduct a pre-agreement visit to ensure the application is accurate and meets the selection criteria and stocking requirements. 

b. The Missouri WIC program will review the results of the pre-agreement visit. If the requirements are not met during the visit, the retailer can make corrections to meet them. A second pre-agreement visit could be required. 

5. Complete new retailer training. 

a. The owner(s) and a designated store representative(s) (e.g., manager) must attend new retailer training in person. Training attendees are then responsible for training all employees. Retailers with a pharmacy must also ensure that pharmacy staff are trained. 

b. The Train-the-Trainer Form must be completed and returned within 30 days of the store’s authorization. Failure to complete the training and return the form could result in termination of the WIC Retailer Agreement. 

6. Pass the level III certification for point of sale (POS) systems conducted by the Missouri WIC program. 

a. Retailers must pass a level III certification to verify that the POS system can accept WIC transactions. Certifications can be completed over the phone by the Missouri WIC program. The certification will be assessed to ensure that the POS system can complete the following: 

i. Balance inquiry (BI).

ii. WIC void (benefit reversal).

iii. WIC transaction (purchase). 

iv. Provide accurate receipts. 

7. Sign the WIC Retailer Agreement. 

a. Upon completing a successful pre-agreement visit, new retailer training, and level III certification, the retailer must sign the WIC Retailer Agreement. 

8. Receive a letter of authorization from the Missouri WIC program.

A. Selection criteria 

The Missouri WIC program has established criteria for selecting retailer applicants who may be authorized to transact WIC food benefits. Authorized retailers must meet all selection criteria throughout the agreement period and may be reassessed at any time during the agreement period. The Missouri WIC program will terminate the agreement if the retailer fails to comply with the current retailer selection criteria outlined in WIC retailer policy 2.2 Retailer Selection Criteria. The criteria below do not apply to pharmacy only retailers. 

Missouri WIC program selection criteria require retailers to meet the following conditions: 

• Provide a POS system capable of conducting WIC transactions. Refer to page 12 for the requirements for being designated WIC capable.
• Operate a full-service grocery store.
• Maintain authorization to accept SNAP. Retailers must not be disqualified from SNAP.
• Remain open at least six days per week, from 9 a.m. to 6 p.m. daily, and post retailer hours.
• Maintain a minimum of 1,000 square feet of space allocated solely for food products, including WIC and non-WIC food.
• Meet the full-service selection criteria stocking requirements for authorized Missouri WIC retailers. See Appendix A.1 for full-service stocking requirements.
• Meet the minimum inventory stocking requirements for WIC-approved food. See Appendix A.2 and A.3 for stocking requirements.
• Purchase infant formula from an approved source listed on the WIC Retailer Distributor, Wholesaler and Manufacturer List.
• Derive no more than 50 percent of sales from selling WIC food.
• Demonstrate business integrity. The Missouri WIC program will not authorize any retailer if, during the last six years, they have been disqualified from a USDA Food and Nutrition Service (FNS) program or if any of the retailer’s current owners, officers or managers have had a civil judgment entered against them for, or have been convicted of, any activity indicating a lack of business integrity. The Missouri WIC program shall determine which offenses apply.
• Have no conflict of interest. The retailer must be free of any conflict of interest between the retailer and the Missouri WIC program, or its contracted providers as defined by applicable state laws, regulations and policies.
• Demonstrate business stability. The retailer must be an established business that has been open to the public for at least one year in the current location or under new ownership in a location continuously open for at least one year or must own and operate at least one currently authorized WIC retailer business in good standing in Missouri.
• Meet pricing requirements. The pricing peer group shall determine whether a retailer meets the program's pricing requirements and whether authorized WIC retailers exceed the average peer group prices for the assigned peer group. Prices of all WIC-approved food must be posted on the shelves or on the products. 

B. Selection criteria to maintain authorization 

Missouri WIC program selection criteria require retailers to maintain the following conditions:

• Transact at least $3,600 in WIC sales revenue annually. Any retailer that fails to maintain the minimum sales may be terminated from the program and cannot reapply for authorization for one year from the agreement termination date. Note: Pharmacy only retailers are exempt from this requirement.
• Transact WIC sales without a lapse of 60 days or more. Any retailer without WIC sales activity for 60 days or more may be terminated from the program. Any retailer terminated from the WIC program due to WIC sales inactivity cannot reapply for authorization for one year from the agreement termination date. Note: Pharmacy only retailers are exempt from this requirement.
• Purchase infant formula from an approved source listed on the WIC Retailer Distributor, Wholesaler and Manufacturer List.
• Maintain a positive sanitation history, as evaluated by the Missouri WIC program’s current food establishment regulations (Missouri Food Code). 

The Missouri WIC program reserves the right to make exceptions to (i.e., waive) the retailer selection criteria to address inadequate participant access to authorized WIC retailers and sets the parameters for defining an inadequate participant access area. However, pricing and minimum WIC-approved food stocking requirements cannot be waived per federal regulations. For more information, refer to WIC retailer policy 2.5 Retailer Inadequate Participant Access. 

C. Adherence to WIC regulations

 Retailers who apply to be an authorized WIC retailer indicate their intent to comply with all WIC regulations as outlined in the Retailer Agreement, Retailer Manual and in 7 CFR 246.12. 

D. Inadequate participant access 

At the Missouri WIC program’s discretion, a retailer may be authorized outside the normal authorization process when a retailer is situated in an area of inadequate participant access to authorized WIC retailers. This may include instances in which a previously authorized Missouri WIC retailer changes ownership under circumstances that do not permit timely notification to the Missouri WIC program. The determination of inadequate participant access areas shall be made by and is solely at the discretion of the Missouri WIC program. 

If the Missouri WIC program determines that disqualification of a retailer from the WIC program due to disqualification from the SNAP program would result in inadequate participant access to authorized WIC retailers, the Missouri WIC program will assess a civil money penalty (CMP) in lieu of disqualification, as explained in the retailer violations section. A CMP will not be issued in lieu of a disqualification for a third or subsequent sanction. Disqualification from the Missouri WIC program due to disqualification from the SNAP program is not subject to administrative or judicial review under the WIC program. 

Situations causing inadequate participant access may be the result of, but are not limited to: 

• Disqualification of an authorized retailer.
• Change of ownership or location of an authorized retailer.
• Disaster or other cause resulting in the loss of, or access to, an authorized retailer. 

The Missouri WIC program may determine whether adequate participant access exists by reviewing criteria, including, but not limited to: 

• The number of authorized retailers available to serve participants in an area.
• Access to public transportation.
• Geographic barriers that make it difficult for a participant to access an authorized retailer. 

The Missouri WIC program may declare a situation of inadequate participant access to accommodate special populations (e.g., migrant workers and their families) and respond to sudden or unexpected population changes to address inadequate participant access. 

For more information, refer to WIC retailer policy 2.5 Retailer Inadequate Participant Access. 

E. EBT capability requirements 

Prior to accepting WIC benefit cards for purchases, retailers must implement a certified system that performs online WIC transactions in accordance with published rules, policies and specifications, including: 

• WIC EBT Operating Rules
• WIC EBT Technical Implementation Guide 

To ensure the integrated electronic cash register (ECR) system you own or plan to purchase is certified for WIC, contact: 

Custom Data Processing (CDP) 
Jim Chilcoat-Retailer Relationship Manager 
Office: 502-695-1999 or Cell: 859-779-5332 
Email: jim.chilcoat@cdpehs.com 

The following requirements must be met: 

• EBT capable systems
  • The retailer must demonstrate the capability to accept WIC benefits electronically (i.e., the retailer has an EBT capable register system) prior to authorization and comply with WIC operating rules, standards and technical requirements, such as those in the WIC EBT Technical Implementation Guide.
• Minimum transaction types
  • At a minimum, the system shall be able to process a balance inquiry (without requiring a purchase to be made), purchase and WIC void (benefit reversal) in compliance with 7 CFR 246.12(h)(3)(xxi) and 7 CFR 246.12(bb)(1).
• Liability
  • The retailer must accept liability for any redemption of WIC benefits 1) for which an approval has not been received from Missouri WIC and 2) for the incorrect redemption of benefits (e.g., providing an item not authorized by Missouri WIC or not available in the cardholder’s account).
• Approved Product List (APL)
  • The retailer must ensure that the most current Missouri APL is downloaded to the ERC system or stand-beside device.
• Receipts
  • The ERC system or stand-beside device must provide the WIC cardholder with a receipt which, at a minimum, shows the store name and address, the date of the transaction, product(s) purchased, price charged for each purchase, and the remaining balance of available benefits.
• Maintenance
  • The retailer must be capable of maintaining the certified ERC integrated system or stand-beside device in a manner necessary to ensure system availability for WIC processing during all hours the store is open for business.
• Personal identification number (PIN)
  • The retailer must ensure the WIC redemption process requires the WIC cardholder to use a PIN in a manner that protects the security of the PIN and in which no one other than the WIC cardholder will have knowledge of the PIN. 

F. WIC capable POS systems 

For WIC retailer authorization, a retailer applicant must demonstrate that their POS system can accurately and securely obtain WIC food balances, successfully complete WIC purchases and obtain the necessary file, the APL. For this situation, retailers with POS systems determined not to be WIC capable will be issued a stand-beside system. Authorized Missouri WIC retailers must comply with the WIC operating rules, standards and technical requirements established by the USDA and the Missouri WIC program. The Missouri WIC program shall not pay ongoing maintenance or operational costs for retailer systems and equipment used to support WIC EBT unless the retailer is needed to address inadequate participant access to authorized WIC retailers. 

a. Integrated POS systems

An integrated POS system can conduct mixed basket transactions. A mixed basket transaction includes WIC and non-WIC items and, therefore, requires more than one tender type. However, it does not require WIC customers to separate their WIC food from non-WIC food and non-food items. 

b. Stand-beside POS system

A stand-beside POS system cannot conduct mixed basket transactions. WIC customers shopping at authorized Missouri WIC retailers with a stand-beside POS system must separate their WIC food from non-WIC food and non-food items. It is important to know how to complete a WIC transaction. Missouri uses online technology (magnetic stripe), in which the card is swiped. 

c. EBT systems

Retailer staff or technical support must resolve any hardware or software problems related to WIC transactions. The Missouri WIC program is not responsible for servicing retailer equipment. 

Failure to take corrective action to ensure WIC transaction processing equipment is operational may result in a sanction. Retailers must download the APL at least every 48 hours to ensure they have the most up-to-date APL, which creates and updates a list of WIC-approved products in the retailer’s POS system. Failure to download a current APL may result in financial liability to the retailer in the following situations: 

• The WIC customer is allowed to purchase a food item that is no longer on the APL.
• The Missouri WIC program may require repayment from the retailer for payments already made to the retailer due to improperly transacted WIC purchases, such as unapproved food, non-WIC items or items with sales tax charged. 

G. Minimum lane requirements 

Retailers are required to have a minimum number of terminals installed based on the retailer’s monthly WIC redemption levels. The monthly WIC redemption levels used for the POS terminal installation formula shall be the average redemptions based on up to 12 months of prior redemption, per federal regulation 7 CFR 246.12(z)(2). 

Minimum lane coverage requirements and POS terminal deployment are as follows: 

a. Stores considered superstores or supermarkets 

At a minimum, terminals shall be installed for monthly WIC redemption threshold increments as follows: 

• One terminal for $0 to $11,000. 

• Two terminals for $11,001 to $22,000. 

• Three terminals for $22,001 to $33,000. 

• Four terminals for $33,001 and above. 

b. Stores not considered superstores or supermarkets 

At a minimum, terminals shall be installed for monthly WIC redemption threshold increments as follows: 

• One terminal for $0 to $8,000. 

• Two terminals for $8,001 to $16,000. 

• Three terminals for $16,001 to $24,000. 

• Four terminals for $24,001 and above.

H. Grocery stores with pharmacy additional requirements 

Grocery stores with pharmacies shall be expected to meet the full-service selection criteria stocking requirements and EBT capability requirements, as well as order WIC-approved formula through the pharmacy (as outlined in Section III). 

I. Pharmacy only retailers 

Pharmacy only retailers are authorized to provide WIC-approved formula that can only be ordered through a pharmacy, as identified in sections 2 and 4 of the WIC Retailer Food and Formula Reference Guide. Pharmacies are not authorized to sell any other types of WIC food items or infant formula that can be purchased through an authorized Missouri WIC retailer’s distributor or wholesaler, identified in sections 1 and 3 of the WIC Retailer Food and Formula Reference Guide. 

For more information, refer to WIC retailer policy 3.1 Pharmacy Only Retailers.

The WIC Retailer Agreement is between a retailer and the Department of Health and Senior Services. The agreement authorizes a retailer to conduct transactions for WIC participants to redeem food benefits under state and federal requirements (7 CFR Part 246.12). 

It is important that retailers review the entire WIC Retailer Agreement and understand all expectations set forth by the Missouri WIC program before signing it. 

The retailer must comply with the agreement's provisions and all federal and state laws, statutes, policies, procedures, manuals and regulations of the Missouri WIC program, including any changes made during the agreement period. Failure to comply will result in the termination of the agreement. This agreement is not a license or property interest. 

The Missouri WIC program is not required to issue an agreement to an applicant, a previous retailer whose agreement has expired or an applicant purchasing an authorized WIC retailer location. It is at the program's sole discretion whether to issue an agreement. Pharmacy only retailers will only be considered for authorization in areas where there are insufficient full-service grocery stores with pharmacies available to meet WIC participants’ needs. This determination is made solely by the Missouri WIC program. 

A. Agreement period 

Agreements are normally effective for three years, beginning October 1 and expire at midnight on September 30. Throughout the agreement period, agreements may be issued to new retailers, with all agreements expiring on the same date. New retailers authorized during an agreement period will be given an agreement for the remainder of the current agreement period. The Missouri WIC program reserves the right to refuse any new applications during the last 120 days of the current agreement period or during any timeframe identified by the Missouri WIC program. No retailer shall accept WIC cards prior to the date specified on the WIC Retailer Agreement or after the expiration date of their WIC Retailer Agreement. 

B. Agreement categories 

The agreement categories are based on the types of foods for which a retailer is authorized to transact WIC cards.

C. Authorization of multiple store locations 

Retailers with multiple store locations are not automatically entitled to have all store locations authorized. Each store location must be evaluated against all selection criteria as if it were a single, independent entity and will be individually listed on the agreement attachment for the corporation agreement. 

By signing the WIC Retailer Agreement, a retailer with multiple store locations accepts responsibility for the program operations of all participating store locations, which are listed in the agreement in Attachment B. All store locations will be assessed, categorized and treated as individual retailers, not as one unit. 

Retailers may request additions or deletions of individual store locations. These are subject to the same review procedures as single-location applicants and shall be effective upon the Missouri WIC program's signature on the agreement amendment. 

D. Notification of retailer changes 

The retailer must notify the Missouri WIC program at least 60 days before making any of the changes listed below. The Missouri WIC Retailer Agreement is not transferable, and any of the changes below will make the agreement null and void. 

Changes requiring a new application and agreement, which must go through the authorization process, include: 

• Location.
• Ownership (e.g., sale of business, new tax identification number). 

Changes requiring a new application and an amendment to the agreement include: 

• Retailer name.
• Category (e.g., full-service grocery store to full-service grocery store with pharmacy).
• Ownership (e.g., co-owner buyout, addition of co-owner). 

Either party may terminate a WIC Retailer Agreement for cause by giving at least 30 days' advance notice to the other party. Retailers are responsible for ensuring that the POS provider deactivates the WIC capability of each electronic cash register (ECR) within the store to prevent WIC transactions upon the date of termination. 

E. Retailer confidentiality

Confidential retailer information is any information about a retailer (whether obtained from the retailer or another source) that individually identifies the retailer, except for the retailer's name, address, telephone number, website, email address, category and authorization status.

At the end of a retailer agreement period, the retailer must complete the reauthorization process to establish a new retailer agreement. The Missouri WIC program will initiate the reauthorization process approximately four months before the end of the retailer agreement period. The expiration of the WIC Retailer Agreement is not subject to appeal. 

A moratorium on the authorization of new retailers will be effective during the reauthorization period to ensure active retailers are authorized without disruption in service. An exception to the moratorium may be granted when there is inadequate participant access to authorized WIC retailers. For more information, refer to WIC retailer policy 2.6 Retailer Reauthorization. 

A. Application 

The Missouri WIC program will initiate the reauthorization process by providing retailers with an application to be considered for reauthorization. Retailers may be considered for reauthorization at the end of the retailer agreement period by submitting the completed application to the Missouri WIC program. Prior to reauthorization, the retailer’s application will be reviewed, and the WIC program will determine whether the retailer continues to meet the WIC program's selection criteria and requirements. Items reviewed and evaluated by the Missouri WIC program upon receipt of the reauthorization application include: 

• WIC transaction information.
• Complaints, violations and sanctions.
• Monitoring and compliance reports.
• Training attendance. 

B. Reauthorization requirements 

Retailers must continue meeting the initial application requirements and meet the following: 

• Attended required WIC training.
• Resolved and responded in writing to all concerns brought to the retailer’s attention by the Missouri WIC program at least sixty days prior to reauthorization.
• Paid fees from any sanctions at least sixty days prior to reauthorization.
• Submitted the completed reauthorization application by the due date. 

C. Reauthorization process 

Before the retailer agreement period ends, the Missouri WIC program will review the reauthorization requirements to determine current retailers’ eligibility for reauthorization. Missouri WIC will send a reauthorization application packet to eligible retailers. Upon return of the completed authorization packet, all information will be reviewed and verified by the Missouri WIC program. If all information is complete and acceptable, a Missouri WIC Retailer Agreement will be sent to the retailer. If additional information or clarification is needed, the Missouri WIC program will contact the retailer. The retailer must sign and return the Missouri WIC Retailer Agreement to the Missouri WIC program. 

If a retailer does not complete the reauthorization process and return the agreement to the Missouri WIC program prior to the end of the expiring retailer agreement period, the retailer must cease transacting WIC purchases and reapply during the new agreement period. 

Any retailers who are deemed ineligible for reauthorization will receive a letter explaining any unmet requirements.

Supplemental foods are prescribed for participants based on their nutrient content (e.g., they contain iron, calcium, protein, vitamin A or vitamin C). WIC food items must meet federal nutrient requirements as outlined in 7 CFR Part 246. Please refer to the current Missouri WIC APL for details on allowable brands, flavors, sizes and varieties.

A. APL

The APL details the specific supplemental foods offered by Missouri WIC. Only WIC-approved foods in the types, quantities and sizes prescribed to the participant may be purchased. Approved products are subject to change.

B. WIC mapping

Mapping is linking a UPC or “retailer-assigned” code to a Price Look-Up (PLU) code. All retailers with an integrated system must use IFPS-specific PLU codes. All retailers with a stand-beside device can use the generic PLU code “4469” or “94469” for organic. Any fresh, pre-packaged produce must be mapped. Mixed, fresh produce must be mapped by picking one of the fruits or vegetables in the package. WIC customers could be prevented from using their WIC cards to purchase fresh produce that is not mapped in retailers’ systems, as the Missouri APL does not contain all UPCs for fresh produce. 

Details on mapping WIC fresh produce are available in the WIC Mapping training. For more information on WIC mapping, refer to WIC retailer policy 2.8 WIC-approved Food and WIC Mapping.

Item	UPC	PLU
Broccoli	000651111025	Map to 4-digit code “4060.”
Oranges	014668130016	Map to 4-digit code “4385.”
Mixed Berry Bowl	0662915	Map to any of the following 4-digit codes: Blackberries “4239.” Raspberries “4244.” Blueberries “4240.”

C. WICShopper app

The WICShopper app is available for use by Missouri participants and retailers. Features include a current food list and the ability to scan a UPC to determine if it is on the Missouri APL. The free app can be downloaded from the App Store and Google Play Store. 

For more information, see the WICShopper App Flyer.

D. Product submission

If you believe an item should be WIC-approved, but it is not included in the APL, email the Missouri WIC program to request that it be added. The email must include clear pictures of the label, UPC, size and ingredients. 

Submit product information to this email address for consideration: WICFoods@health.mo.gov.

A. Stocking groups 

Authorized Missouri WIC retailers fall into one of two stocking groups.

• Tier 1: Stores with annual WIC sales of $65,000 or below.
• Tier 2: Stores with annual WIC sales above $65,000. 

For more information, refer to WIC retailer policy 2.8 WIC-approved Food and WIC Mapping. 

B. Failure to meet minimum stocking requirements 

WIC-approved grocery and grocery with pharmacy retailers must maintain the minimum stocking requirements through the agreement period. Failure to maintain the minimum stocking requirements may result in sanctions or disqualification. 

For more information, refer to Appendix A.2 Minimum Stocking Requirements Tier 1 and Appendix A.3 Minimum Stocking Requirements Tier 2. 

C. Infant formula 

The Missouri WIC program participates in an infant formula rebate contract. The Department contracts with a specific infant formula manufacturer that agrees to give the WIC program a rebate for each unit of their infant formula purchased at the retailer with WIC benefits. This rebate is used to offset the program’s cost for food purchased with WIC benefits. The infant formulas included in the rebate contract are called “primary contract formulas.” 

Authorized Missouri WIC retailers are not required to stock concentrates and ready-to-use formulas, but if these formulas are available through the retailer's distributor or wholesaler, they must be made available for a WIC customer within 72 hours. If a requested formula is not available to order through the retailer’s wholesaler or formula distributor, advise the WIC customer to contact their local agency for assistance.  

Only pharmacies that are authorized Missouri WIC retailers can accept WIC cards for WIC approved formulas that must be ordered through a pharmacy and cannot be ordered through an authorized Missouri WIC retailer’s distributor or wholesaler. Please reference the WIC Retailer Food and Formula Reference Guide.

a. Distributors 

All authorized WIC retailers are required to obtain formulas sold to WIC participants from an approved manufacturer, distributor or wholesaler with a valid Federal Tax Identification Number. For a listing of WIC authorized formula sources, please view the WIC Retailer Distributor, Wholesaler and Manufacturer List or contact the Missouri WIC program. 

b. Formula exchanges 

WIC customers are not allowed to exchange infant formula purchased with WIC benefits unless the item is damaged, defective or expired and the WIC customer is requesting the exact same formula item. If a WIC customer wants a different formula, they should be referred to their local agency. 

In the example below, a WIC customer purchased Similac Total Comfort with their WIC benefits but found the can had expired. They requested an exchange for the exact same item, which can be processed at the store. 

In the example below, a WIC customer purchased Similac Total Comfort with their WIC benefits but requested an exchange for a different formula, which cannot be processed at the store. The WIC customer should take the formula they wish to return to their local agency to request a change to their benefits. 

For more information, refer to WIC retailer policy 2.9 Retailer Substitution, Exchange, Refunds and Recalls. 

c. Pharmacy ordered formula buyback 

The Missouri WIC program may authorize a “buyback” of WIC-approved formula only when an authorized Missouri WIC retailer has ordered the formula through the pharmacy for a WIC customer and not all the ordered formula is purchased. This buyback ensures that authorized Missouri WIC retailers are not required to absorb the cost of the unpurchased WIC formula from a pharmacy. The primary contract formula will not be included in a buyback. 

The formula buyback occurs as follows: 

• The retailer must contact the Missouri WIC program retailer manager.
• The retailer informs the Missouri WIC program retailer manager of the type, size, quantity, UPC and expiration date of the WIC-approved formula ordered through the pharmacy.
• Note: Formula that has expired or will expire within 60 days of the retailer notifying the Missouri WIC program is NOT eligible for the buyback.
• The retailer must provide the wholesale price and the retail price they charged for the formula purchased by the pharmacy.
• The Missouri WIC program retailer manager will determine if the formula meets the criteria for buyback.
• If the formula meets the buyback requirements, a Missouri WIC program staff person will purchase the formula. 

d. Tips for pharmacy ordered formula 

Troubleshooting tips for pharmacies when ordering WIC-approved formula: 

• The pharmacy cashier can conduct a WIC balance inquiry to ensure that the customer is requesting the correct formula, including the approved flavor.
• All units should be scanned individually. Do not scan the UPC located on the case, as only the unit UPC is entered into the APL.
• Do not use the multiplier key when scanning items.
• If a retailer is unable to order or obtain a WIC-approved formula from their distributor, please refer the WIC customer to contact their local agency.
• It is recommended to do smaller transactions based on the number of items purchased to reduce potential errors during checkout.
• The WIC Retailer Food and Formula Reference Guide is a helpful resource used by warehouses, retailers and pharmacies to ensure they are allowing the current approved formulas. It also provides the National Drug Code (NDC) for ordering.

A. Retailer peer groups 

Authorized WIC retailers are assigned to a retailer peer group based on their geographic classification and business model category. Retailer peer groups establish competitive price allowances for WIC-approved foods among retailers in each category, helping ensure WIC foods are offered at competitive market prices. Once retailers are grouped, competitive price criteria are applied, and a “not-to-exceed” (NTE) amount is established for each WIC-approved food item within each peer group. The Missouri WIC program will inform retailers of their peer group assignment and may change retailer peer group assignments as necessary to maintain effective peer grouping. 

B. Pricing requirements 

Retailers must not exceed prices posted on shelf tags. Retailers may not charge WIC customers more for WIC-approved food than they charge other customers. 

C. Competitive price selection criteria 

Retailers must maintain competitive prices within their peer group for WIC-approved food. Competitive pricing is UPC pricing that is within 15 percent above the average price charged for a WIC-approved item. 

The Missouri WIC program’s EBT system captures authorized retailers’ WIC card transaction prices for each UPC daily, and a periodic analysis is conducted to determine an average price for each UPC. Special or sale pricing is not included in the analysis. If a retailer’s price on a specific UPC is not within the 15 percent variance allowed for competitive pricing within their peer group, the retailer will be notified that the price on that UPC must be reduced to a competitive price. The Missouri WIC program will send a competitive price selection criteria price survey form identifying the retailer’s UPC prices that do not meet competitive pricing within their peer group. If the retailer still sells that UPC, they must reduce the price on the UPC and submit the new price to the Missouri WIC program or submit a justification for why the price cannot be reduced. If the retailer does not submit the new reduced price or justification for why the UPC’s price cannot be reduced, and the retailer maintains non-competitive pricing, the retailer will be assessed for inadequate participant access. Retailers not in an inadequate participant access area will receive a termination letter for not meeting competitive pricing criteria.

WIC transactions may look and work differently depending on your store’s POS system. Most stores will integrate the WIC purchases into their cash register system; however, a few may use a separate piece of equipment, known as a stand-beside system, that is certified to accept WIC transactions. 

WIC cards cannot be used at self-checkout lanes or at registers in the liquor sections or gas stations.

Instructions on how to complete WIC transactions (e.g., WIC balance inquiry, purchase, void (benefit reversal) and mapping) can be obtained through your POS provider or by contacting the Missouri WIC program.

A. What can be purchased? 

Only the food items and quantities on the WIC card may be purchased. WIC participants must receive the WIC-approved food item that corresponds specifically to the UPC code scanned by the retailer during the transaction. A participant cannot buy more than the total quantity of food on their WIC card, and that appears on their WIC receipt. Where brand names are specified, only those brands can be purchased. A cash value benefit (CVB) is issued to some WIC participants for the purchase of fruits and vegetables. The WIC participant may purchase fresh and/or frozen fruits and vegetables meeting WIC guidelines. The dollar value of the CVB varies based on the value of the benefits the participant has been issued. 

B. Redemption in Missouri only 

Missouri WIC cards may be redeemed at any authorized Missouri WIC retailer. WIC customers can redeem WIC benefits for WIC-approved food and formula. Pharmacy only retailers may only accept WIC cards for special formula. Missouri WIC cards cannot be redeemed at retailers outside of Missouri. Additionally, WIC cards from other states cannot be redeemed at Missouri retailers. 

C. Valid dates of use 

Benefits will start on the first day of each month at 12:00 a.m. and will be valid through the last day of each month until 11:59 p.m. Any transactions occurring on the last day of the month must be complete by midnight Central time.

D. WIC balance inquiry 

At the participant’s visit to the WIC clinic, an itemized food benefit list showing their WIC food items is provided to use as a shopping list at the store. In addition to the WIC food benefit list they receive at the clinic, participants have other options to request their current WIC balance: 

• At the store, a balance inquiry can be printed at the register with a WIC card and PIN.
• Participants can call the phone number on the back of their WIC card to inquire about their remaining balance.

E. Completing a WIC transaction 

• The cashier scans all items.
• The cashier presses the WIC tender button.
  • The button could be named differently based on the POS system.
• The WIC customer swipes their card and enters their PIN.
  • Two receipts print. The Beginning Balance receipt and the Redemption receipt, which show the WIC customer what is covered and not covered by their benefits.
• The WIC customer reviews the receipts.
• The WIC customer presses "Accept" or "Decline" on the PIN pad.
• The transaction is finalized.
  • An Ending Balance receipt prints, which shows the WIC customer their remaining benefits. 

If no balance remains and the WIC transaction has been completed, a WIC void (benefit reversal) CANNOT be completed. Any items removed from the card must be given to the WIC customer.

F. WIC void (benefit reversal)

There must be a balance remaining to complete a WIC void. Some systems may not be capable of completing a WIC void. 

A WIC void is generally completed for the following reasons: 

• The WIC customer doesn’t have funds to pay the remaining balance.
• The WIC customer no longer wants the item.
• The WIC customer selected the wrong item. 

G. Receipts 

The receipts obtained during a WIC transaction will contain information regarding the customer’s beginning balance, the redemption receipt (showing WIC items that will be purchased if approved), an ending balance (showing remaining benefits) and the final store receipt. 

All receipts must be given to the WIC customer as they print. The cashier must not keep or throw away any receipts. 

H. WIC split tender 

Split tender maximizes WIC customers’ cash value benefit (CVB) for fruit and vegetable purchases by allowing them to pay a remaining balance for fresh fruit and vegetable purchases that exceed the CVB amount available. 

For example, if a WIC customer purchases a bag of apples priced at $2.49 but only has $2.00 remaining in CVB on their WIC card, split tender allows the WIC customer to apply the remaining $2.00 to the cost of the bag of apples, and the balance of $0.49 will move to the non WIC total. This allows the WIC customer to “split” the cost of the bag of apples between WIC food benefits and an alternate tender type.

I. Identification-PAN and PIN 

To make a WIC purchase, the customer must have a WIC card and a PIN. Cashiers can manually enter the card number (PAN) if the WIC card cannot be read by the store’s PIN pad. Under no circumstances can the 16-digit PAN be manually entered without the WIC cardholder presenting the actual WIC card. Cashiers should not check alternate forms of identification for a WIC purchase or ask the participant for their PIN. Page 24 Retailer Manual 

J. Coupons, store specials, sales and discounts 

WIC customers must be offered the same courtesies that are offered to other customers, including but not limited to, in-store promotions, such as: 

• Buy One, Get One Free (BOGO).
• Buy One, Get One at a Reduced Price (BOGOR).
• Transaction Discount ($ or % off an entire transaction).
• Store Loyalty or Rewards Cards.
• “Cents Off” Discount Coupons. 

K. Incentive items 

Authorized Missouri WIC retailers must offer WIC customers the same courtesies offered to non-WIC customers and vice versa. WIC customers must not be treated differently from non WIC customers by exclusion from in-store promotions. WIC customers may not be offered incentive items that are not offered to non-WIC customers. Offering incentive items solely to WIC customers is prohibited by federal regulations. 

L. Exchanges, recalls and returns 

Retailers may not allow WIC customers to exchange any WIC food for a cash refund, merchandise or other food items. When there is a food safety issue or recall for a product other than formula, identical exchanges should be made when possible. When an exchange is not possible, contact the Missouri WIC program at MOWICVendorGroup@health.mo.gov or 573-751-6204 for appropriate instructions. If you receive a recall notice on infant formula, contact the Missouri WIC program for instructions. 

M. Substitutions 

The retailer may not provide unapproved food items, non-food items, cash or credit (including rain checks) in exchange for WIC cards or WIC benefits. Scanning any UPC code that is not affixed to the actual item being purchased by the WIC participant, or any UPC code as a substitute, replacement, or otherwise not actually affixed to the actual item being purchased by the WIC participant, is a program violation that will result in a sanction.

N. Tax exemption 

No sales or use tax of any statutory or home rule city, town or county shall apply to the sale of food purchased with funds provided by WIC. WIC customers should not be required to sign a tax exemption letter or form for any WIC transaction. The Missouri WIC program is not subject to Missouri Sales and Use Tax for any WIC transaction. If a retailer’s registers are automatically programmed to add tax to a coupon, the Missouri WIC program will reimburse the amount of tax on the coupon ONLY. The coupon must appear on the receipt. 

O. No charge for WIC items 

Retailers are not allowed to charge the WIC customer cash or credit for the food items covered by the WIC card.  

P. Not-to-exceed price 

WIC sets an NTE price, which is the maximum allowable reimbursement that retailers will receive for a specific WIC food item. This helps control costs and ensures that the program remains within its budget. WIC does not restrict the prices retailers can charge but rather sets the maximum amount WIC will reimburse for each UPC within each peer group. Retailers may charge more than the NTE price for an item, but WIC will only reimburse up to the NTE price. 

• The NTE is based on UPC prices submitted on retailers’ WIC card transactions.
• The system calculates NTE prices for each UPC for each retailer peer group.
• Retailers will only be reimbursed up to the NTE price for their assigned retailer peer group.
• NTE prices on most items are recalculated every two weeks.
• NTE prices can be adjusted more frequently for specific items based on fluctuations in national market prices. 

For more information, refer to WIC retailer policy 2.3 Retailer Pricing and Peer Groups and WIC retailer policy 2.4 Retailer Competitive Price Selection Criteria. 

Q. Scanning issues 

Sometimes, scanned items are not accepted as WIC items, even though they appear to be WIC-approved items. Some reasons a customer’s item may not scan as WIC-approved when the customer tries to redeem benefits include: 

• The item is not WIC-approved.
• The WIC customer does not have enough benefits.
• The WIC customer does not have the item as a benefit.
• The item is WIC-approved but has not been WIC mapped.
• The POS system has not downloaded the current APL file. 

R. Payments to retailer 

Transactions will be processed through the retailer’s third-party processor (TPP). A retailer will receive payment within 48 hours only if the WIC transaction is properly completed. A transaction will not be authorized by the Missouri WIC program if: 

• The maximum amount allowed is exceeded.
• The transaction is manipulated.
• Benefits are redeemed by a retailer outside of Missouri. 

The retailer is responsible for the review of all WIC transactions. If a transaction has been rejected by the Missouri WIC program, please call the Missouri WIC program at 573-751-6204.

The WIC Retailer Agreement requires the retailer to allow the Missouri WIC program or its designee to monitor the retailer for compliance. 

During a monitoring visit, the retailer shall provide access to purchase orders or invoices for WIC-approved food, shelf price records and all retail and storage areas. 

For more information, refer to WIC retailer policy 5.1 Retailer Compliance.

A. Overt monitoring visits (routine) 

Upon arrival at the store to conduct routine monitoring, Missouri WIC monitoring staff will introduce themselves to a retailer representative and perform the following: 

• Verify the retailer’s name.
• Verify that WIC Door Decals and retailer hours are posted at all entrances. 
• Verify that WIC Approved Shelf Tags are placed on all WIC-approved foods, except in the produce section.
• Verify that the retailer is meeting the stocking requirements.
• Review prices to verify that WIC transaction prices and shelf prices match prices at the register.
• Review or confirm the current version of the POS system to detect updates.
• Review or confirm the retailer’s training procedures for personnel handling WIC.
• Inspect the sanitary conditions of the store, which includes storage areas, coolers and freezers.
• Verify that the packaging of all WIC-approved food is in good condition and within the expiration date.
• Conduct or observe a WIC transaction.
• Request a copy of the infant formula invoice to ensure the infant formula was purchased from an approved distributor.
• Conduct an exit interview. 

For more information, refer to WIC retailer policy 5.4 Retailer Overt Monitoring Visits.

B. Covert monitoring visits (compliance buys) 

The Missouri WIC program may perform compliance buy investigations of any retailer at any time during the agreement period. Investigators will perform covert buys to determine whether the retailer is complying with the program’s federal and state rules and regulations, as outlined in the WIC Retailer Agreement, policies and this manual. 

The Missouri WIC program has the right to demand repayment for payments already made on improperly transacted or redeemed WIC cards, and for charges of more than the price displayed on the retailer’s shelf. The Missouri WIC program may also issue sanctions that may include fines, termination of the WIC Retailer Agreement or disqualification from the WIC program. 

For more information, refer to WIC retailer policy 5.6.

C. WIC mapping and technical assistance monitoring 

The Missouri WIC program may perform mapping compliance monitoring at any retailer during the agreement period. Monitors choose up to ten fresh produce items in the store. The items are then taken to a cashier to conduct a WIC transaction to determine if they are mapped to an appropriate 4-digit PLU code. For any items that are not mapped, the monitor will provide technical assistance to the store or corporate office to map the items appropriately.

D. Sales and inventory audit 

The Missouri WIC program may perform WIC inventory audits of any retailer at any time during the agreement period. 

The WIC sales transaction audits may cover a three-year period, but generally cover 30 to 90 days. The retailer must provide the Missouri WIC program copies of all WIC-approved stock invoices for the specific period requested within 15 days of the date on the written request.

An inventory audit will include an inventory count before and after the sales transaction, and the audit information will be collected. Targeted food items will be counted. 

Failure to provide the requested documentation may result in a claim for repayment of WIC funds paid to the retailer, as outlined in the WIC Retailer Agreement, policies and this manual. 

At the completion of the WIC sales transaction and inventory audit, the Missouri WIC program has the right to demand refunds for payments already made on improperly transacted or redeemed WIC cards and for charges of more than the retailer’s actual selling price. 

For more information, refer to WIC retailer policy 5.5 Retailer Inventory Audits.

A. Role of WIC retailers 

Full-service grocery stores and pharmacies play an essential role in improving the nutritional health status of women, infants and children in the Missouri WIC program. The retailer’s role is to provide WIC customers with the food items issued on their WIC card, only in the designated brands, quantities, sizes and types. These foods provide WIC customers with the specific nutrients they need and reinforce the nutrition education received from the local agency. In accordance with WIC retailer policies and procedures outlined in the WIC Retailer Agreement and the WIC Retailer Manual, WIC customers receive the nutritious food items that have been prescribed, and authorized WIC retailers receive payment for the items customers purchase with WIC food benefits. 

All retailers and pharmacy owners must understand how the Missouri WIC program operates. Each authorized Missouri WIC retailer is responsible for complying with all program policies, procedures and regulations.

B. WIC Retailer Manual and Retailer Agreement 

The Missouri WIC Retailer Manual and Retailer Agreement define the roles and responsibilities of retailers. By reference, this WIC Retailer Manual is made part of the Retailer Agreement, and the policies and procedures outlined in this manual are an integral part of the Retailer Agreement. The Retailer Agreement, Retailer Manual, federal regulations and policies must be met by each authorized WIC retailer. Missouri WIC may terminate the Retailer Agreement by providing 15 days' advanced written notice to the retailer, except in the case of a permanent disqualification. The retailer may terminate the Retailer Agreement by providing 30 days' advance written notice. The parties shall not be released from the duty to perform their obligation up to the date of termination. Neither Missouri WIC nor the retailer has an obligation to renew the agreement. 

C. Policy changes 

Clarifications, changes and/or additions to WIC policies and procedures may be made throughout the agreement period. The USDA may also approve waivers to allow exemptions from certain regulations. Any changes will be communicated to retailers through mail, email and the MO WIC Scoop. Retailers must subscribe to receive important emails via GovDelivery.

A. New retailer training 

All new applicants must attend a new retailer training, even if the owner previously attended training as a representative of another authorized WIC retailer location. If the applicant is new to the Missouri WIC program, the owner(s) and a designated retailer representative (e.g., manager) must attend the training. Training attendees are then responsible for training managers, cashiers and other absent retailer staff responsible for WIC. Failure to attend training will result in the denial of the application. The Missouri WIC program will determine the location of the in-person training. 

For more information regarding new retailer training, refer to WIC retailer policy 4.2 New Retailer Training. 

B. Mandatory training 

Retailers are required to attend mandatory training if they receive a violation or have failed to submit the required corrective action plan for any violation. Retailers failing to attend the required training will receive further sanctions, up to disqualification from the program or a CMP. The Missouri WIC program will determine the location of the training. 

C. Annual training 

Annual training may be conducted in person, virtually, through a Missouri WIC newsletter or via another method determined by the Missouri WIC program. It must be conducted in an interactive format at least once every three years. 

For more information, refer to WIC retailer policy 4.3 Annual Retailer Training.  

D. Technical assistance training 

The Missouri WIC program offers retailers hands-on WIC technical assistance (TA) training. Training can be held at your store or regionally, depending on the interest in your area. The goal is to equip your cashiers, managers, price coordinators and scanning coordinators with the skills to complete WIC transactions and other WIC-related actions successfully. TA training content will include topics such as the following: 

• How to conduct a WIC transaction.
• WIC card procedures.
• Troubleshooting tips.
• What to do with receipts.
• How to review receipts.
• Minimum varieties and quantities of WIC-approved foods.
• Compliance with the WIC program.
• WIC mapping fresh produce. 

These training sessions will ensure that WIC shoppers have a great shopping experience. You can register by emailing Angela.Easley@health.mo.gov.

A. WIC acronym and logo 

Retailers are not authorized to use the WIC acronym or logo, or close replicas, in advertising and other promotional materials or in the retailer's name. 

Retailers who use the WIC acronym and/or WIC logo in an unauthorized manner will receive a sanction and be required to remove the WIC acronym and/or WIC logo. 

Retailers must obtain Missouri WIC program approval to use the WIC acronym or logo in their electronic tags or price tags. Please submit the WIC Retailer Request to Use WIC Acronym in Electronic Tags or Pricing TagsArchived form. 

For more information, refer to WIC retailer policy 2.11 Retailer Use of the WIC Acronym and Logo.

B. Reporting fraud and abuse 

If you encounter a WIC participant who you suspect is misusing WIC, please report this to the Missouri WIC program. Examples of actions to report include: 

• Return of items purchased with WIC.
• Verbal or physical abuse.
• Attempts to obtain cash or credit in a WIC transaction (e.g., returning to the store with a discount card after the transaction is complete). 

To report fraud or abuse, retailers should contact the Missouri WIC program with questions or to resolve initial problems. Reports of abuse and/or complaints should be made as soon as possible. Buying, selling or otherwise misusing WIC benefits is a crime. To report suspected fraud or abuse, complete the WIC Fraud and Abuse Form.

C. Payment disputes 

Retailers will be paid for all valid WIC transactions submitted to the Missouri WIC program. An authorized Missouri WIC retailer may dispute a reduced transaction payment; however, the Missouri WIC program does not guarantee that dispute requests will be approved. 

The Missouri WIC program must receive a dispute request within sixty days of the transaction date. 

The WIC Retailer Request for Additional Payment form must be requested from the Missouri WIC program and submitted to MOWICVendorGroup@health.mo.gov for payment consideration. 

Per federal regulation 7 CFR 246.12(k)(5), if the total value of transactions or claims disputed at one time exceeds $500, the Missouri WIC program must obtain approval from the Food and Nutrition Service (FNS) Regional Office before executing payment.

If the retailer’s dispute is denied, the retailer will receive written notification explaining the reason for the denial.

D. Lost cards 

If a WIC customer leaves their WIC card in your store: 

• Call the Missouri WIC program at 573-751-6204 within the same business day to provide the card number for deactivation.
• Destroy the card immediately. 

Retaining WIC cards is a state violation.

E. Communications

Authorized Missouri WIC retailers and pharmacies must communicate with the Missouri WIC program if they have questions or need assistance. Retailers must provide current email addresses, phone numbers and mailing addresses. Retailers must also subscribe to receive emails through GovDelivery. For changes to contact information, complete the WIC Retailer Communication FormArchived.

F. Conflict of interest 

Conflict of interest is prohibited between WIC and the retailer and between the local agency and the retailer. A conflict of interest exists when there is a monetary relationship between the retailer and the Missouri WIC program or the local agency. Additionally, a conflict of interest also exists when relatives serve WIC participants. Missouri WIC shall terminate the Retailer Agreement if it identifies a conflict of interest between the retailer and the Missouri WIC program or a local agency.

G. Retailer complaints 

A retailer may submit a Retailer Concern FormArchived with any problems, concerns or suggestions to the Missouri WIC program or the local agency. 

For more information, refer to WIC retailer policy 5.8 Retailer Complaints.

A. Retailer violations 

Retailer violations may be intentional or unintentional. The Missouri WIC program may refer retailers who commit fraud and/or abuse of the WIC program to federal, state or local authorities for prosecution under applicable statutes. The WIC program has two levels of violations: those that result in Missouri state sanctions and those that result in federally mandated sanctions. 

Imposed sanctions may include warning letters, corrective action plans, mandatory training sessions, administrative fines, monetary claims, civil money penalties (CMPs), suspensions, terminations, disqualification or any combination of sanctions. A retailer committing fraud or abuse of the WIC program is liable for prosecution under applicable federal, state and local laws.

A retailer that has willfully misapplied, stolen or fraudulently obtained WIC program funds shall be subject to a fine of not more than $25,000 or imprisonment for not more than five 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 year, or both, per 7 CFR 246.12(h)(3)(xxi). 

The Missouri WIC program must provide written notice of any sanctions imposed against a retailer. The notice must specify the sanction being imposed, its effective date and the reason for the sanction.  

For more information, refer to WIC retailer policy 6.2 Retailer Violations and exhibit 6.1A Retailer Sanction Schedule. 

B. Corrective action plan (CAP) 

When a violation requires corrective actions, the retailer shall prepare a CAP. The CAP must address the area of violation and may include training to educate retail staff on WIC program policy and procedures, customer service or a plan to address stocking issues. The plan must include a timeline for addressing the issue and a follow-up plan to ensure requirements are completed. The CAP must be submitted within the time frame stated in the monitoring letter. Failure to submit the required CAP will result in an immediate $50 fine without further notice or warning. A $100 fine will be issued for any subsequent failure to submit a CAP. Failure to submit the required CAP is a state violation. 

C. CMP in lieu of disqualification 

The Missouri WIC program will assess a CMP in lieu of a retailer’s disqualification only if the disqualification would result in inadequate participant access as defined by the Missouri WIC program. The CMP amount is calculated as ten percent of a retailer’s average monthly WIC redemptions multiplied by the number of months the retailer would have been disqualified. A retailer’s average monthly WIC redemption is based on the monthly WIC redemption for the previous six months. 

D. CMP in lieu of permanent disqualification 

For a violation that warrants permanent disqualification (Federal Class “A” #1), the amount of the CMP will be determined by 7 CFR 3.91(b)(3)(vi). If multiple violations are found during a single investigation, the Missouri WIC program may impose a CMP for each violation. 

E. Termination for noncompliance 

WIC Retailer Agreements may be terminated due to a retailer’s noncompliance with the WIC program selection criteria and/or the WIC Retailer Agreement. Examples of noncompliance that may result in termination of the WIC Retailer agreement include, but are not limited to: 

• Failing to meet the competitive price selection criteria.
• Failing to meet the minimum square footage requirements.
• Failing to meet the minimum stocking requirements of a full-service grocery store.
• Failing to meet other WIC program selection criteria and/or WIC Retailer Agreement requirements.
• Failing to reimburse the state agency for improperly transacted WIC card purchases or WIC sales transaction audits. 

For more information on termination, refer to WIC retailer policy 2.7 Retailer Agreement Expiration and Termination.

F. False or misleading sales information

The Missouri WIC program will immediately terminate the WIC Retailer Agreement, disqualifying the retailer, for a pattern of providing false or misleading sales transaction information to the WIC program. A pattern for this violation is defined as three or more compliance buys where false information has been supplied within a federal fiscal year. This includes fraudulent WIC sales transactions that were submitted for payment. 

A pattern may also be established due to the retailer resubmitting four or more previously rejected WIC card transactions for payment that have been altered or as a result of the findings from a WIC sales transaction audit within a federal fiscal year. For any instance of a retailer resubmitting a previously rejected WIC card transaction for payment that has had its date of sale or the amount of sale altered, the retailer will receive a warning and a fine of $50. The state sanction for these patterns of violations is a one-year disqualification. 

G. Definitions for sanction schedule 

• Retailer violation. Any intentional or unintentional action of a retailer’s current owners, officers, managers, agents or employees (with or without management knowledge) that violates the WIC Retailer Agreement or federal or state statutes, regulations, policies or procedures governing the program.
• Investigation. A method used by the Missouri WIC program to determine if violations are occurring.
• Sanction. An administrative action taken as a result of a violation.
• Pattern. Based on the number and severity of the violations. 

H. JetPay 

Need to pay fines or reimbursements? Use JetPay to make a one-time payment.

Class “A” and “B” violations are subject to mandatory federal sanctions as defined in 7 CFR 246.12 and shall constitute grounds for disqualification from the WIC program.

A. Federal Class A violations 

Federal Class “A” violations: Include conviction or an incident of trafficking (buying or selling WIC food instruments or CVB) or selling firearms, ammunition, explosives, controlled substances, alcohol, alcoholic beverages or tobacco products in exchange for WIC cards.

B. Federal Class B violations 

Class “B” violations occur when there is a pattern of violations. A pattern for these violations is three or more instances of the same Class “B” violation during any federal fiscal year (October 1 to September 30).

The Missouri WIC program will impose state sanctions. The number of occurrences of a violation of the Missouri WIC program is based on the same violation. The violation must be established by a pattern of the same violation within a federal fiscal year.

A. Missouri violations 

The table below details the corrective action required for state violations and the increasing severity of those violations when they are not corrected.

For more information on state violations, refer to WIC retailer policy 6.1 Retailer Sanctions, WIC retailer policy 6.2 Retailer Violations and exhibit 6.1A Retailer Sanction Schedule.

A. Administrative review for adverse actions 

The Missouri WIC program must impose sanctions, CMPs, denials of authorization, terminations or other adverse actions on retailers for noncompliance with federal and state statutes, regulations, policies and procedures governing the WIC program. When an adverse action is imposed, authorized WIC retailers may request an administrative review within 15 days. A uniform administrative review process evaluates the noncompliance and the adverse action applied. Based on the type of noncompliance, a full or abbreviated administrative review process will be completed. The administrative review process is outlined below.

B. Notification to retailers 

The Missouri WIC program will notify retailers in writing when the state agency imposes an adverse action. At a minimum, the notification will include: 

• The adverse action.
• The cause(s) for the adverse action.
• The effective date of the adverse action.
• The retailers’ right to request an administrative review and the procedures to request a review, including relevant time periods and deadlines.

C. Retailer administrative review request 

The retailer or applicant must provide the Missouri WIC program with a written request for an administrative review within 15 days of receipt of the notice of denial or other adverse action. The written request must describe the adverse action being appealed. The retailer or applicant must fully comply with all appeal processes or forfeit appeal rights. 

The Missouri WIC program may postpone the effective date of an adverse action until the decision of an administrative review is rendered. Requesting an administrative review does not relieve a retailer from the obligation to comply with the terms of all written agreements or contracts with the Missouri WIC program. The retailer is permitted to continue participating in the program while the review is pending. 

D. Failure to request an administrative review 

The retailer who fails to request an administrative review or does not make the request within the 15-day period may not contest the subsequent adverse actions taken by the Missouri WIC program.

F. Full administrative review

The retailer or applicant has the right to a full administrative review for the following adverse actions:

• Denial of authorization based upon:
  • Application of the retailer selection criteria for minimum variety and quantity of approved supplemental foods.
  • A determination that the retailer is attempting to circumvent an adverse action.
• Termination of an agreement for cause.
• Disqualification, except those disqualifications subject to abbreviated administrative review.
• Imposition of a fine or CMP instead of disqualification.

When a retailer or applicant has requested an administrative review for an adverse action requiring a full administrative review, the Missouri WIC program will provide the retailer with the following procedural information:

• No less than ten days' advance notice of the time and place of the administrative review so all parties can prepare for the review.
  • The opportunity to present its case and one opportunity to reschedule.
• The opportunity to cross-examine witnesses. A protective screen or other device may be used to protect the identity of WIC program investigators when necessary.
• The opportunity to be represented by counsel.
• The opportunity to call witnesses.
• The opportunity to examine the evidence causing the adverse action prior to the review.
• An impartial decision-maker to review whether the Missouri WIC program has correctly applied federal and state statutes, regulations, policies, and procedures.

G. Abbreviated administrative review

The retailer or applicant has the right to an abbreviated administrative review for the following adverse actions: 

• Denial of authorization based upon:
  • Denial of authorization based on retailer selection criteria for business integrity or for a current SNAP disqualification or CMP for hardship.
  • Denial of authorization based on the application of the retailer selection criteria for competitive pricing.
  • The application of the state agency retailer peer group criteria and the criteria used to identify retailers that are above-50-percent retailers or comparable to above-50-percent retailers.
  • Denial of authorization based on the state agency-established retailer selection criterion if the basis of the denial is a WIC retailer sanction or a SNAP withdrawal of authorization or disqualification.
  • Denial of authorization based on the state agency’s retailer limiting criteria (7 CFR 246.12(g)(2)).

The retailer or applicant has the right to an abbreviated administrative review for the following adverse actions: 

• Denial of authorization based upon:
  • Denial of authorization based on retailer selection criteria for business integrity or for a current SNAP disqualification or CMP for hardship.
  • Denial of authorization based on the application of the retailer selection criteria for competitive pricing.
  • The application of the state agency retailer peer group criteria and the criteria used to identify retailers that are above-50-percent retailers or comparable to above-50-percent retailers.
  • Denial of authorization based on the state agency-established retailer selection criterion if the basis of the denial is a WIC retailer sanction or a SNAP withdrawal of authorization or disqualification.
  • Denial of authorization based on the state agency’s retailer limiting criteria (7 CFR 246.12(g)(2)).
  • Denial of authorization because a retailer submitted its application outside the timeframes during which applications are being accepted and processed as established by the state agency under (7 CFR 246.12(g)(8)).
  • Termination of an agreement because of a change in ownership or location or cessation of operations (7 CFR 246.12(h)(3)(xvii)).
  • Disqualification based on a trafficking conviction (7 CFR 246.12(l)(1)(i)).
  • Disqualification based on the imposition of a SNAP civil money penalty for hardship (7CFR 246.12(l)(2)(ii)).
  • Disqualification or a civil money penalty imposed in lieu of disqualification based on a mandatory sanction imposed by another WIC state agency (7 CFR 246.12(l)(1)(iii)).
  • A civil money penalty imposed in lieu of disqualification based on a SNAP disqualification under 7 CFR 246.12(l)(1)(vii).
  • Denial of an application based on a determination of whether an applicant retailer is currently authorized by SNAP. 

When a retailer or applicant has requested an administrative review for an adverse action requiring an abbreviated administrative review, the Missouri WIC program will provide the retailer with the following procedural information: 

• No less than fifteen days to provide a written response to the adverse action.
• A decision-maker to use the available information to determine whether the Missouri WIC program has correctly applied federal and state statutes, regulations, policies and procedures governing the program. The decision-maker will be someone other than the person who made the initial decision on the action.

H. Final decision 

The Missouri WIC program will provide the retailer or applicant with written notification of the final decision within 90 days of receiving the retailer’s or applicant’s request for an administrative review. The timeframe is only an administrative requirement for the Missouri WIC program and does not provide a basis for overturning the program’s adverse action if a decision is not made within the specified timeframe. 

The Missouri WIC program is not responsible for losses incurred by the retailer due to disqualification or denial of an application to participate. Administrative review decisions are final. The retailer may pursue judicial review of the decision to the extent authorized by law if the administrative review decision upholds the adverse action. 

For more information on retailer appeals, refer to WIC retailer policy 7.1 Retailer Appeals.

Authorized Missouri WIC retailers must stock and meet the full-service selection criteria requirements for authorized WIC retailers as listed below. For more information on full-service selection criteria, refer to WIC retailer policy 2.2 Retailer Selection Criteria or the Retailer Manual.

Authorized Missouri WIC retailers must stock the following items in specified quantities to meet the WIC requirements. Retailers with annual WIC sales of $65,000 or below must meet Tier 1 stocking requirements. Refer to the WICShopper app and Minimum Stocking Requirements for WIC-approved foods and where to place Missouri WIC Shelf Tags. 

For items listed as “Upon request,” retailers must order the item within 72 hours if it is available from their warehouse or distributor. 

Authorized Missouri WIC retailers must stock the following items in specified quantities to meet the WIC requirements. Retailers with annual WIC sales above $65,000 must meet Tier 2 stocking requirements. Refer to the WICShopper app and Minimum Stocking Requirements for WIC-approved foods and where to place Missouri WIC Shelf Tags. For items listed as “Upon request,” retailers must order the item within 72 hours if it is available from their warehouse or distributor.