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.