WIC Operations Manual (WOM) Definitions

1.1.010 Local Agency and Authorized WIC Retailer Coordination

Effective: 10/2025

Issued: 01/1981

Authority references: 2025 7 CFR 246.12(r)(3); 246.12(h)(3)(xx); 246.12(t)

Policy:

The local agency (LA) shall collaborate with the state agency (SA) retailer unit and local authorized WIC retailers, as needed, for questions regarding food benefits, WIC transactions, complaints, training and retailer concerns.

The LA must designate a WIC staff member to act as the retail liaison.

The LA shall inform the SA retailer manager which store(s) in their service area are owned or co-owned by a member of the LA governing body.

Procedures:

1. Coordinating retailer processes.
   1. The LA is responsible for ensuring that appropriate LA staff can:
      1. Contact the authorized WIC retailer to determine if they have a WIC food item in stock that is a part of the participant’s food benefits.
         1. If an item is not in stock, the LA may ask if the authorized WIC retailer is able to order the food item from their warehouse or contact the SA retailer unit for assistance.
         2. If a formula is out of stock at the retailer, refer to policy 2.3.130. b. Address participant, authorized representative, alternate representative and proxy complaints regarding an authorized WIC retailer or issues with the food instrument and food benefits.
         3. Process and file a complaint to the SA retailer unit.
         4. Provide information from policy 8.1.080 and educate participants, authorized representatives, alternate representatives and proxies on the retailer's redemption processes.
      2. The LA staff shall not in any way influence the participant’s choice of retailer.
      3. Processing complaints and troubleshooting food instrument issues.
         1. The LA must use the Retailer and WIC card redemption complaints form to submit complaints against an authorized WIC retailer or to report WIC card issues. Encourage the participant to provide as much information as possible to expedite the investigation process.
      4. The LA must refer to the SA retailer unit for specific retailer issues, such as, but not limited to, WIC-approved food stocking, tagging and monitoring.
2. Retailer liaison roles and responsibilities.
   1. The retailer liaison role designation must be indicated in the local agency plan (LAP) and is responsible for the following:
      1. Acting as the point of contact for the SA retailer unit.
      2. Disseminating information to LA staff on changes to retailers in their area.
      3. Ensuring LA compliance with the procedures listed above.
   2. Training requirements.
      1. Refer to the All WIC Staff Training Chart for training requirements and policy 2.4.010 for maintenance of training records.
3. Retailer liaison roles and responsibilities.
   1. A member of an LA board of trustees, county court commission or city council must not vote on any WIC retailer-related issues if that individual is an authorized WIC retailer or interested in becoming an authorized WIC retailer.
   2. Failure of an LA to provide information to the SA regarding a governing council member who is the owner or co-owner of an authorized WIC retailer or is interested in becoming an authorized WIC retailer will result in sanctions as deemed appropriate by the SA.
   3. The SA will terminate the WIC Retailer Agreement if the SA identifies a conflict of interest, as defined by applicable state laws, regulations and policies, between the authorized WIC retailer and the LA.

1.1.020 Issuance Frequency

Effective: 04/2026

Issued: 10/2009

Authority references: 2025 7 CFR 246.12(r)(5)

Policy:

Benefits must be issued to participants in a one-month, two-month or three-month supply (i.e., monthly, bi-monthly or tri-monthly issuance) that is appropriate for them.

At certification, the nutritionist or competent professional authority (CPA) (i.e., professional staff) must assign the participant’s Issuance Frequency in the Management Information System (MIS). Only professional staff can assign or change the Issuance Frequency, and it should reflect the maximum supply of benefits appropriate for issuance.

It is prohibited to issue a greater supply of benefits than is appropriate, but staff may issue a smaller supply of benefits to accommodate scheduling needs.

Procedures:

1. Professional staff must determine the maximum supply of benefits appropriate for issuance based on the following:
   1. Monthly issuance:
      1. Infants up to 1 month of age.
      2. Women less than four weeks postpartum (after delivery or pregnancy termination for any reason).
         1. Blood work should ideally be collected between four and six weeks postpartum, but cannot be collected before four weeks postpartum.
      3. Participants who have not met their nutrition education contacts.
      4. Breastfeeding women with complications (i.e., risk factor 602).
      5. Participants certified in the labor, delivery, recovery and postpartum (LDRP) hospital setting.
      6. High-risk women, infants and children who have not been assessed by a nutritionist.
      7. Participants who are missing anthropometric or bloodwork data.
   2. Bi-monthly issuance:
      1. Infants 1-6 months of age.
      2. Breastfeeding and nonbreastfeeding women one to six months postpartum (benefit issuance matches the infant).
      3. Foster children in short-term care.
      4. High-risk women, infants and children who have been assessed and determined appropriate for bi-monthly issuance by a nutritionist.
      5. Pregnant women certified during their third trimester.
         1. Pregnant women should be scheduled frequently enough to offer essential breastfeeding and nutrition information that is both critical and timely during the brief prenatal period.
   3. Tri-monthly issuance:
      1. Breastfeeding women six months or more postpartum.
      2. Infants 6 months of age or older.
      3. Children.
      4. Women, infants and children with resolved high-risk risk factors.
      5. Nonbreastfeeding women four weeks to six months postpartum, who have experienced a pregnancy loss or whose infant is not in their care.
      6. Pregnant women in their first or second trimester.
      7. Homeless or migrant participants.
2. Any reason for issuing a supply of benefits greater than appropriate, as determined in section A above, must be documented in the MIS.
   1. Participants assigned a monthly Issuance Frequency may initially and temporarily be switched to bi-monthly at certification to receive two months of benefits if they receive a prorated food package for the first month. After the initial issuance, the Issuance Frequency must be reassessed and adjusted based on section A above.
3. Refer to policy 8.1.160 for guidance on assigning Issuance Frequency when a participant transfers to another state’s WIC program.

1.1.030 Food Instrument Inventory, Accountability and Replacement

Effective: 06/2025

Issued: 01/1981

Authority references: 2025 7 CFR 246.12(p) and (q), 246.23(a)(4)

Policy:

The food instrument is the electronic benefits transfer card (i.e., WIC card) which is used by the participant, authorized representative, alternate representative or proxy to obtain supplemental foods.

The local agency (LA) is responsible for maintaining, ordering and securing food instrument inventory to ensure inventory is adequate to meet operational needs.

The LA is responsible for tracking the disposition of food instruments from receipt until issuance.

The LA must deactivate a food instrument within one business day of the authorized representative, alternate representative or proxy reporting it as lost, stolen or damaged and provide a replacement food instrument within seven business days of the report.

Any unredeemed food benefits from the current month remain with the household and must be accessible with the replacement food instrument.

Procedures:

1. Maintaining inventory and accountability controls.
   1. The LA is responsible for food instrument inventory management. Inventory management must include the following:
      1. Verifying receipt of the food instruments by signing and returning the required forms to the state agency (SA).
      2. Reconciling food instrument inventory on a routine basis (i.e., weekly or monthly).
         1. Complete the Food Instrument Bundle Inventory form (WIC28).
      3. Storing all food instrument inventory forms for the main site and satellite site(s), either electronically or in paper form, in a secure location. Refer to policy 10.1.070.
         1. All food instruments must be stored and secured at all times, including any time LA staff travel with the food instruments.
2. Disposition of food instruments.
   1. The LA must ensure each food instrument is properly:
      1. Issued within the Management Information System (MIS) to an eligible participant with a valid certification.
      2. Deactivated in the MIS when a participant is terminated due to ineligibility or violation or when the food instrument is reported as lost, stolen or damaged. Refer to policies 8.1.170, 10.1.020 and 11.1.030.
3. Processing lost, stolen, damaged and replacement food instruments.
   1. Only the authorized representative, alternate representative or proxy designated in the MIS can report a food instrument as lost, stolen or damaged and obtain a replacement. Refer to policy 8.1.190.
      1. The individual may use the customer service line provided on the back of the food instrument to report a lost, stolen or damaged food instrument but must obtain a replacement at the LA.
   2. The LA must verify the identity of the authorized representative, alternate representative or proxy before deactivating a food instrument or issuing a replacement by viewing a form of acceptable identification listed in policy 8.1.210 or asking the following validation questions:
      1. Their name.
      2. The last four digits of the card number, if the card is available and numbers are visible.
      3. The primary cardholder’s date of birth (DOB).
      4. The household mailing address zip code.
   3. Once identity is verified, deactivate the food instrument within one business day of the report and issue a new food instrument within seven business days.
      1. Provide referral information for local food resources when needed.
   4. The authorized representative, alternate representative or proxy must sign for receipt of the new food instrument in the MIS or on the WIC Signature Pad Backup Form (WIC-25).
      1. The primary cardholder designation may change based on who obtains the new food instrument.
         1. Refer the cardholder to the customer service line for resetting the personal identification number (PIN) as needed.
      2. The LA must retain all documentation of signed receipts of food instruments.
   5. Destroy any unusable, damaged or replaced food instruments.

3.1.010 Equipment Inventory

Authority: 2019 7 CFR 246.24(d), 246.25(a), 2 CFR 200.313

Issued: 01/1981

Revised: 10/2019

Policy:

The local agency (LA) shall use state agency (SA)-provided WIC inventory tags to identify equipment purchased with WIC funds by the LA and the SA.

The LA shall maintain an inventory list of all equipment purchased with WIC funds, both by the LA and the SA.

The LA shall reconcile the WIC equipment inventory biennially and record the date of reconciliation. All changes to the location or disposition of the WIC equipment shall be submitted to the SA.

All equipment purchased with WIC funds by the LA and by the SA belongs to the SA and must be returned to the SA if the LA discontinues WIC services.

Equipment purchased jointly with WIC funds and other funds must be inventoried according to the procedures below.

Procedures:

1. For inventory purposes, the LA shall permanently tag all equipment in the categories below purchased with WIC funds. In addition, the LA shall permanently tag all other equipment with a useful life of more than one (1) year and an acquisition cost of at least $500.00 purchased with WIC funds. The SA will supply WIC inventory tags to the LA. The equipment to be tagged includes, but is not limited to:
   1. Computers (desktops, laptops, and tablets)
   2. Computer monitors
   3. Printers
   4. Scanners
   5. Signature pads
   6. Network switching equipment (including routers, hubs, etc.)
   7. Hemoglobin analyzers
   8. Anthropometric equipment (scales and height boards)
   9. Card reader/writers
2. The LA shall maintain a multi-user hospital grade electric breast pump inventory, even if the replacement cost is less than $500. (See policy 2.1.030.)
3. The LA shall maintain and update an inventory list of all equipment purchased with WIC funds. A physical verification of all equipment will be performed during LA biennial monitoring visits to be matched with SA property records. The LA inventory list shall contain all of the following information:
   1. Description and type of equipment (e.g., computer, monitor, printer)
   2. Serial number, if available
   3. WIC inventory tag number
   4. Model number/manufacturer name, if available
   5. Date of purchase (only for LA-purchased equipment)
   6. Purchase price (only for LA-purchased equipment)
   7. Percent of WIC funds used, if purchased jointly
   8. Site where equipment is located
   9. Status of equipment (e.g., currently using, spare, broken, lost or stolen)
4. The LA equipment inventory may be integrated into the overall local administrative agency's inventory. However, equipment purchased with WIC funds must be so designated. Equipment purchased jointly with WIC funds and other funds must indicate the total acquisition cost and the portion funded by WIC. When determining if jointly purchased items must be inventoried, the total acquisition cost of the equipment is the basis of the determination.
5. Prior to purchasing new equipment not budgeted and approved as part of the local agency plan (LAP), the LA shall submit the request to purchase equipment to their technical assistant (TA) for approval. (Refer to policy 5.1.070.) WIC inventory tags will be mailed to the LA if the equipment is to be tagged.
6. All equipment used for the WIC program shall be properly maintained and repaired as needed, and be kept secure from theft or vandalism.
7. Upon request of the SA, the LA shall make the equipment inventory list available within five (5) business days. The LA shall also allow the SA to inspect the equipment and inventory tags upon request.
8. The LA shall obtain written authorization from the SA before doing any of the following with WIC-purchased equipment:
   1. Loaning
   2. Transferring
   3. Trading
   4. Selling
   5. Destroying
   6. Removing from the inventory list
9. The LA shall retain Department of Health and Senior Services’ Non-Expendable Property Transfer/Reassignment forms (DH-60), utilized to update the location and status of equipment, to ensure accuracy of inventory.
10. The LA shall retain inventory lists until notified by the SA that it has been a minimum of three (3) years following the date of submission of the final expenditure report for the period to which the inventory list pertains or until resolution of any issues resulting from an audit or other action that may arise, whichever is longer. The SA will notify the LA when inventoried items may be removed from the inventory list.

3.1.020 WIC Equipment: Temporary Loan, Repair and Replacement

Authority: 2008 7 CFR 246.6(b)(1) and 246.16(d)(2)

Issued: 01/1993

Revised: 10/2009

Policy:

The local agency (LA) shall be responsible for assuring equipment purchased with WIC funds or purchased by the state agency (SA) and placed for use in a LA's facility, are available to conduct WIC program services.

All equipment shall meet SA requirements and comply with the SA specifications, be properly maintained and repaired as needed, and kept secure from theft or vandalism.

The LA must pay from non-WIC funds for replacement or repair of equipment purchased with WIC funds that was damaged, lost or stolen due to LA negligence.

Procedures:

State-owned Equipment:

1. The LA is responsible for appropriate security and use of any state-owned equipment while it is in the possession of the LA.
2. If any state-owned WIC equipment is damaged, lost, stolen or becomes unusable while in the possession of the LA, repair or replacement will be handled as follows:
   1. The SA will pay for replacement or repair of the equipment when due to:
      1. Natural phenomenon (for example, flood, fire etc.)
      2. Normal wear and tear from extended use.
      3. Other circumstances beyond the LA's control.
   2. The LA must pay from non-WIC funds for replacement or repair of the equipment when due to LA negligence or other circumstances within the LA's control.

LA-owned Equipment:

1. When dealing with WIC-purchased equipment, the LA will report problems and proposed steps to correct the problems to the SA.
2. The SA staff will recommend repair or replacement, depending on which is the most cost effective.
3. When billing on the WIC Monthly Administrative Cost Invoice (WIC-24):
   1. Repair costs are billed on the "Administrative Office Costs" line item. Refer to policy 5.1.090.
   2. Equipment costs are billed on the line item appropriate to the purchase. Refer to policies 5.1.070 and 5.1.110.
4. The LA may request a budget amendment to repair or replace the equipment.
   1. The SA will give a budget amendment only if funding is available and projections show that the LA will exceed the contract by the end of the fiscal year.
   2. If repair is more cost effective than replacement, but the LA chooses replacement, then the budget amendment will be for no more than the cost of the repairs.
5. The LA must assure that all WIC functions continue to be done appropriately while the equipment is being repaired or replaced. The SA will provide loaner computer equipment to the LA; however, the SA will not provide loaner health assessment equipment to the LA.

3.1.030 Income Guidelines

Authority: 2008 7CFR 246.7(d)

Issued: 10/1990

Revised: 10/2009

Policy:

The state agency (SA) shall implement the new income guidelines at the same time when MoHealthNet (Medicaid) implements the new income guidelines each year. The income guidelines will not exceed 185% of poverty level.

The local agency (LA) shall use the income calculator in the Missouri WIC Information Network System (MOWINS) to determine income eligibility for the program at certification and recertification.

Procedures:

1. The SA will assure that MOWINS is kept current with income guidelines changes each year.
2. The SA will supply the LWP with copies of the income guidelines to use for assessment purposes when the data system is not available. Refer to ER# 3.02000.
3. The SA will post the income guidelines on the state WIC web site and also send the income guidelines to appropriate referral agencies as needed.
4. When new applicants are prescreened, the LA can determine income eligibility at their initial inquiries using the income calculator in MOWINS.
5. The LA may publish the specific income guidelines as part of their outreach efforts.

3.1.040 WIC Applications Access, User IDs, Passwords and Security

Authority: 2008 7 CFR 246.26(d)

Issued: 01/1993

Revised: 10/2022

Policy:

To maintain proper security and participant confidentiality, each individual who accesses any WIC data system must have their own user identification (user ID) and password.

Local agency (LA) staff are prohibited from sharing individual user IDs and passwords or using user IDs and passwords that are not their own. In the event an individual’s user ID and password is compromised, the LA will be held responsible for the violation and the sanction guidelines outlined below will be followed.

LA staff shall log out of WIC applications when away from a shared computer or when another person will be working at their computer. LA staff shall activate a password protected screen saver before leaving their computer.

An Automated Security Access Processing (ASAP) form for new employee Missouri WIC Information Network System (MOWINS) access shall not be submitted until the MOWINS Security Training is complete.

LA administrator or WIC coordinator shall ensure an ASAP form is submitted to delete all WIC access on the last day of employment when an individual no longer needs WIC access or if employment is terminated for any reason.

Procedures:

1. LA staff shall complete an ASAP request form to gain, change or remove access to WIC data, MOWINS, WIC electronic reports, web-based Local Agency Plan (LAP), web-based WIC Online Invoicing or additional data systems.
   1. Retain a copy of all ASAP requests for three (3) years in a central file for monitoring purposes.
2. User IDs and passwords are an important aspect of computer security. All LA staff, contractors, subcontractors and any other temporary staff person or person(s) with access to any WIC application(s) must have unique user IDs and personal passwords. All staff and contractors need to comply with the following:
   1. Be responsible for all information entered and functions performed for the entire period they are logged on.
   2. Exercise all security requirements to protect integrity and confidentiality.
   3. Not share their user ID and password with any individual or use another individual’s user ID or password.
   4. Take all precautions and efforts necessary to protect the visual observation of their user ID and password when entered into all WIC applications.
3. When a security violation occurs the state agency (SA) shall utilize the guidelines below. The SA reserves the right to impose stricter sanctions based on the severity of the security violation.
   1. First offense: The SA will contact the LA administrator by phone and issue a warning letter to explain the suspected security violation. The SA will summarize the conversation in an email for documentation purposes.
      1. The LA must provide a corrective action plan (CAP) within 15 calendar days after receipt of the written warning and the corrective action plan must be implemented once approved by the SA. All WIC staff shall complete a mandatory security training as part of the CAP.
      2. The SA recommends that the violator be disciplined according to the LA’s policy.
   2. Second offense: The procedure for the first offense will occur again. In addition, the violator’s access shall be revoked until CAP completion.
      1. A fine of $100 may be imposed, which shall be paid within 30 days using non-WIC funds. Failure to pay the fine may result in the withholding of the monthly WIC administrative cost reimbursement until payment is made.
   3. Third offense: The procedure for the first offense will occur again. In addition, the agency’s or violator’s access to the specific system or all systems will be revoked for up to 30 days.
      1. A fine of $250 may be imposed, which shall be paid within 30 days using non-WIC funds. Failure to pay the fine may result in the withholding of the monthly WIC administrative cost reimbursement until payment is made.
4. When a User ID is compromised or hacked the following will occur:
   1. If LA staff or a subcontractor suspects that a theft, breach or exposure of WIC data or PII has occurred, they must immediately provide a description of the incident via email to the agency assigned SA technical assistants and WICHelpDesk@health.mo.gov, or by calling the MOWINS Help Desk at 800-554-2544. This email address and phone number are monitored by state agency staff who will inform the Office of Administration Information Technology Services Division (ITSD) team.
   2. In a situation where the LA has been hacked and user IDs compromised, all user IDs will be inactivated and new user IDs issued by completing an ASAP request. The ASAP request is the only mechanism to issue new user IDs.

3.1.050 Certification and Appointment Backup Forms

Authority: 2019 7 CFR 246.7(i)

Issued: 10/2009

Revised: 02/2020

Policy:

When the Missouri WIC Information Network System (MOWINS) or computer equipment fails, the local agency (LA) shall use the backup forms provided by the state agency (SA) to collect the minimum required demographic, income assessment, nutrition assessment, nutrition education, food prescription information, and signatures.

Procedures:

1. When MOWINS or computer equipment fails during certification, the LA shall:
   1. Perform the screening procedures to determine program eligibility by completing the WIC Proof of Eligibility (WIC-30) form.
      1. If the participant is found to be ineligible, notify the participant of ineligibility. Refer to 8.1.170.
      2. If the participant is found to be eligible, review the WIC Participant’s Rights and Responsibilities (WIC-10) form and obtain the appropriate signature.
   2. Complete the certification using the WIC Certification – Women (WIC-1) or WIC Certification – Infants and Children (WIC-2) forms according to program category.
   3. Provide the participant explanation. Refer to 8.1.080
2. When MOWINS or computer equipment fails during food benefit issuance or nutrition education, the LA shall:
   1. Provide the nutrition education contact, as scheduled.
   2. Document the nutrition education topic(s) provided and complete the address portion of the WIC Nutrition Education backup form.
3. Advise the authorized representative or proxy the LA will contact them when benefits may be issued.
4. When MOWINS or the computer equipment is restored:
   1. Enter the data collected on the backup forms in MOWINS. Observe separation of duties requirements. Refer to 8.1.030.
   2. Scan the signed WIC Participant’s Rights and Responsibilities (WIC-10) form in MOWINS.
   3. Make an appointment for the participant to return to receive benefits.

3.1.060 Use of Text Messaging, Mass Messaging and Chat

Effective: 10/2025

Issued: 05/2024

Authority references: 2024 7 CFR 246.9(k)(4); 246.26(d)(1); WIC policy memo 2002- 2; WIC policy memo 2023-5; RSMo 37.070, 610.023 and 610.023; Privacy Act of 1974; Telephone Consumer Protection Act

Policy:

Local agencies (LA) may use third-party software and technology solution(s) or tools, approved and/or funded by the state agency (SA), to send emails, text messages, mass messages or two-way chat to promote WIC services and convey information about the WIC program to WIC participants.

All communication sent electronically by an LA to a WIC participant must protect the confidentiality of a WIC participant’s personal identifiable information (PII) and protected health information (PHI) from unauthorized disclosure. The LA must obtain consent from the WIC participant, authorized representative or alternate representative when using electronic methods of communication. Refer to policy 8.1.010.

Procedures:

1. Consent and confidentiality.
   1. At initial certification and upon change of telephone number or change of authorized representative, the LA shall ask the WIC applicant, participant, authorized representative or alternate representative consent to send text messages.
   2. The initial message sent by an LA shall include a simple option for the recipient to opt out of future messages.
      1. An initial message is not required if the system (e.g., Teletask) performs this step automatically.
         1. The participant, authorized representative or alternate representative may reply “STOP” to block incoming messages.
2. Use of WIC messaging tools.
   1. The LA shall use the SA-provided guidelines when sending texts or mass messages related to WIC. Refer to the WIC Messaging Toolkit.
   2. The LA must adhere to policy 11.1.020 when using WIC messaging tools.
3. Permitted use.
   1. All message content sent through an SA-funded messaging tool shall be directly related to the WIC program and services. Refer to the WIC Messaging Toolkit.
   2. The LA shall only initiate messages to current WIC participants for the purpose of engaging in WIC services.
   3. The LA shall only send messages with web links:
      1. To provide approved nutritional education or breastfeeding support post-certification appointment.
      2. Upon request by the participant.
      3. As a mass message to engage a broader participant audience to set up appointments or as an invitation to participate in a class or a WIC survey.
   4. LAs shall provide nutrition services and education in accordance with the approval of remote service plans. Refer to policies 2.4.110 and 8.1.280.
4. Prohibited use.
   1. LAs shall refrain from initiating messages outside of normal business hours or after 8 p.m. Central time, except in cases where the LA needs to relay communication impacting WIC appointments or services.
   2. The messaging tool should not be used to conduct two-way text or chat communication about changes or adjustments to a participant's food package.
      1. Changes to a participant’s food package will require further discussions with a CPA or nutritionist. Refer to the WIC Messaging Toolkit and policy 2.4.110.

4.1.010 Local Agency Personnel: WIC Coordinator

Authority: 2023 7 CFR 246.3(f); 246.6(b); PL 111-296; 246.11(d)

Issued: 08/1997

Revised: 03/2023

Effective: 07/2023

Policy:

The WIC coordinator is responsible for the function, coordination and overall management of the local agency (LA) WIC program. The WIC coordinator shall ensure the LA is managed effectively and efficiently. The WIC coordinator may perform other roles, for example, LA administrator, nurse, nutritionist or clerk.

Procedures:

1. The WIC coordinator is responsible for the following:
   1. Planning and coordinating all WIC activities and staff to ensure goals are met and the agency operates within program guidelines and rules.
   2. Ensure appropriate LA policies and procedures are established and enforced in compliance with federal and state policies and procedures.
   3. Acts as liaison between LA and state agency (SA) staff.
   4. Develops a program plan and evaluation method, in coordination with the local WIC nutrition coordinator.
   5. Monitors the effects of clinic operations by reviewing and evaluating the following:
      1. Appropriate management reports.
      2. Participant chart audits.
      3. Customer satisfaction surveys.
      4. LA policies and clinic workflow.
      5. Clinic and staff work schedules.
         1. To perform the required duties, the WIC coordinator must have access to all appropriate WIC applications, including but not limited to, grants management systems, Crystal Reports BI Portal and Missouri WIC Information Management Systems (MOWINS).
   6. Responds to requests by the SA for information within requested time frames including, but not limited to, the Local Agency Plan (LAP), self-monitoring and corrective action plan to assure program compliance.
   7. Provides input to the SA regarding overall WIC program operations and makes suggestions for statewide improvement.
   8. Ensures coordination of services and referrals between LA programs and other agencies.
   9. Ensures all WIC services are delivered consistently, appropriately and in an adequate time frame to allow participants to receive appropriate program benefits.
   10. Maintains contracted caseload for the LA through ongoing caseload management. 
   11. Develops, coordinates and documents implementation of ongoing outreach activities in the community.
   12. Handles participant complaints, violations and fair hearings in accordance with state policies and procedures. Refer to policy 11.1.020 and 11.1.030.
   13. Ensures appropriate staff is available and properly trained to perform necessary functions. Reviews all new and revised policies annually and provides training to other LA staff. Refer to 2.4.010.
       1. Ensures the LA has provided a nutritionist backup plan in the LAP, on the LA Nutritionist Backup Plan template provided by the SA.
   14. Ensures that food instrument accountability functions are appropriately assigned and performed. This includes a separation of staff duties related to the accountability and control of food instruments. Refer to 8.1.030.
   15. Ensures employees, contractors and volunteers of an LA adhere to policy 8.1.030 in order to maintain program integrity.
   16. Ensures and monitors proper use of the MOWINS database.
   17. Ensures and monitors fiscal accountability and submission of timely and accurate reimbursement requests.
   18. Performs supervisory duties, as assigned by the LA administrator.
   19. Conducts clinic activities and other duties as required.
   20. Acts as a liaison with local contracted retailers or appoints a staff member to act as the retailer coordinator.
   21. Ensures WIC staff maintains a courteous and respectful attitude toward participants in the WIC program.
   22. Ensures food instruments are stocked, tracked, secured and ordered as needed.
   23. Sets up the master calendar for appointment scheduling at the main and satellite clinic sites.
   24. Maintains the local referral list.
   25. Determines the security role(s) of each LA staff member.
   26. Develops written grievance or complaint policy to address non-civil rights issues.
   27. Acts as the National Voter Registration Act (NVRA) liaison or appoints a staff member to act as the NVRA liaison with the local election authority in the agency's service area.
   28. Ensures LA cooperation of studies and evaluations required by USDA.
       1. To strengthen program integrity, LAs are required to cooperate in USDA studies and evaluations.
2. Knowledge, skills and abilities:
   1. Working knowledge of effective management techniques.
   2. Knowledge of current developments in public health and application to the LA.
   3. Ability to work well with people of diverse socioeconomic and cultural backgrounds.
   4. Knowledge of the general organization and function of public health agencies.
   5. Ability to gather, interpret, evaluate and use statistical data.
   6. Demonstrate rapport building skills by establishing and maintaining effective working relationships with WIC participants, WIC team members and other health and social services personnel.
   7. Ability to develop plans, implement action plan(s) and evaluate effectiveness.
   8. Knowledge of basic computer literacy skills.
3. Appropriate positions to be supervised by: LA administrator, Board of Trustees or County Commissioners.
4. Appropriate positions to supervise: any WIC staff, at the discretion of the LA administrator.
5. Preferred qualifications, education and experience:
   1. Graduation from an accredited four-year college or university with specialization in health care administration, nutrition or dietetics, public health, personnel or business administration, biological or social sciences or education.
6. Minimum qualifications, education and experience:
   1. High school graduate plus four years of experience in one or more of the following areas:
      1. Professional or technical experience in public health, nutrition or dietetics, counseling, community organization, research and data collection, business or health care administration, interviewing or closely related fields.
      2. Experience in WIC.

4.1.020 Appropriate Tasks: Administrative/Clerical

Authority: 7 CFR 246.3(f) & 246.4(a)(26)

Issued: 03/1989

Revised: 05/2015

Policy:

Each local agency (LA) shall consider certain WIC tasks to be clerical or administrative and should have appropriate staff performing these duties.

Procedures:

1. Clerical and administrative staff are allowed to perform the following functions depending on their responsibility level within the agency and WIC:
   1. Prescreens applicants and obtains certification data such as demographics and income. Reviews and documents eligibility requirements for proof of income, residency and/or identity and enters them in MOWINS. Updates data and enters notes when appropriate. Refer to policy 8.1.030.
   2. Retrieves Department Common Number (DCN) for individual applicant.
   3. Refers participants to social and community service programs.
   4. Explains to the participant the importance of the WIC folder, keeping their scheduled appointments, and their rights and responsibilities which includes but is not limited to avoiding dual participation and fraud.
   5. Issues food instruments and food benefits.
   6. Explains the program and how to use the food instruments with policy 8.1.080.
   7.  
   8. Schedules appointments.
   9. Prepares information for in-state and out-of-state transfer requests.
   10. Assists in the promotion and support of breastfeeding as the preferred method of feeding.
   11. Follow-up on no-show participants and reschedules appointments.
   12. Conducts outreach activities.
   13. Organizes files.
   14. Manages clinic flow, caseload and finances.
   15. Interviews participants regarding possible fraud or violations.
   16. Completes and submits monthly WIC invoices.
   17. Completes one-on-one food instrument reconciliation.
   18. Retains and destroys records.
   19. Reviews and uses clinic and management reports.
   20. Participates in continuing education activities.
   21. Appropriately records program management, client service and breastfeeding promotion hours on timesheet according to policy.
   22. Prepare and evaluate the state plan (LAP) to assure the goals and objectives chosen can be met.
   23. Reviews all policies and policy updates.
   24. Review reports, WIC updates and emails.
2. Required Knowledge, Skills and Abilities:
   1. Demonstrate rapport building skills by establishing and maintaining effective working relations with WIC participants, WIC team members and other health and social services personnel.
   2. Ability to work well with people of diverse socioeconomic/cultural backgrounds.
   3. Basic computer skills and literacy in using Window Explorer.
   4. Participates in continuing education activities appropriate to position.
3. Minimum Qualifications/Education and Experiences:
   1. High school diploma or equivalency.
   2. Successful completion of state required training within the time designated by state agency.

4.1.030 Using Volunteers

Authority: 2008 7 CFR 246.26(d)(1) & MPSF-1:WC-93-15-P

Issued: 08/1997

Revised: 10/2009

Policy:

The local agency (LA) shall ensure that volunteers who are given access to client information are well trained and knowledgeable of the restrictions on disclosure of this information.

Procedures:

1. The LA shall exercise discretion in screening and selecting capable volunteers who would have access to confidential information. If a potential volunteer does not appear to be a good candidate for keeping information confidential, there may be other activities that the person can perform that would not include access to participation information.
2. Once volunteers are selected, specific job requirements should be covered in the orientation or training of volunteers. Refer to 4.1.020, 2.4.050, 2.4.060, and 2.4.070.
3. The LA shall assure volunteers are familiar with confidentiality requirements and capable of complying. Volunteers are required to sign the same confidentiality agreement signed by LA paid staff. Refer to 8.1.020.
4. Follow-up training can be conducted periodically to remind volunteers of the importance of maintaining the confidential nature of participant information.
5. Supervision should be based on duties of the volunteer.

4.1.040 No-Smoking Policy

Authority: 2008 7 CFR 246.6(b)(4), MPSF-1:WC-94-12-P

Issued: 09/1994

Revised: 10/2009

Policy:

The local agency (LA) shall prohibit smoking on any premises used to carry out the WIC program during the time any aspects of WIC services are performed. LA providing WIC services from satellite locations in leased, rented, or donated space must assure the area is designated no-smoking during the time any aspects of WIC services are performed.

The LA must post the service and waiting areas as non-smoking.

Any LA that allows smoking in the area where WIC program functions are performed will not receive administrative funds from WIC.

Procedures:

1. The LA will either post a public policy against smoking or post no-smoking signs in areas of any facility where WIC program functions are performed. This includes waiting areas.
2. The LA must prohibit smoking during times that the WIC program is actually operating at a clinic site. For example, at satellite sites, such as churches or community centers, the no-smoking policy must be implemented during clinic service hours only.
3. This policy applies to:
   1. Participants/guardians/applicants
   2. LA staff serving participants
   3. Volunteers and visitors
4. For LA staff and volunteers, it is recommended that smoking be confined to official break and lunch times and only in specifically designated smoking areas.
5. Smoking is prohibited near the WIC clinic entrances used by WIC participants.

4.1.050 Local Agency Plan

Effective: 10/2025

Issued: 03/1989

Authority references: 2025 7 CFR 246.5(b) & (f), 246.6, 246.11(c)(1) and (7), and (d)

Policy:

The local agency (LA) must complete a Local Agency Plan (LAP) application in WebGrants prior to the beginning of each federal fiscal year (FFY). The state agency (SA) will set a required LAP submission due date each FFY. The SA must approve the LAP before October 1 of the upcoming FFY.

Procedures:

1. Completing LAP requirements.
   1. Each LAP application must include the following:
      1. Personnel and operational costs budget with narrative.
         1. Allowable WIC costs as defined in the Local Agency Nutrition Services contract (LANS) and section five of the WIC Operations Manual (WOM).
      2. Outreach plan.
      3. Nutrition services back-up plan.
      4. Nutrition and/or breastfeeding goals and objectives.
      5. Required policies.
      6. Contracts, Memorandum(s) of Understanding (MOUs) and Memorandum(s) of Agreement (MOAs).
      7. Other LA information as required.
   2. LAP training.
      1. The SA will provide LAP training annually for LA staff.
      2. The SA may require specific LAs to attend LAP training as part of a corrective action plan (CAP).
      3. LAP tools and resources are available on the LA Portal and should be used to complete the LAP.
   3. Written agreements (e.g., MOUs or MOAs) must be developed with health care providers and health care organizations in the LA service area for referral services. These agreements include the administrative agency, not just the WIC program.
      1. Agreements must include the names and addresses of the private physicians participating, the types of services offered and the clients served.
         1. Program funding must not be used to reimburse private physicians for health services provided.
      2. If developing a written agreement (e.g., MOU or MOA) with each health care provider/organization in the service area is not feasible, the LA must have a written protocol for making health services available, describing how providers will be contacted to ensure WIC participants can be referred to them.
2. LAP review and approval process.
   1. The SA will review LAP applications for each FFY.
      1. This process may include negotiation between the SA and LA if changes are necessary.
   2. The LA will be notified when the LAP is approved.
   3. If disapproved, the SA will provide notice of the reasons for disapproval and the right to an appeal.

4.1.060 Emergency and Disaster Preparedness for Local Agencies

Authority: 2019 7 CFR 246.7(c)(2)(i); 246.7(g)(3); WIC Policy Memo 95-9A Revision of WIC Disaster Policy and Coordination; 95-9B Clarification of WIC PM 95-9A; 2017 Guide to Coordinating WIC Services During Disasters

Issued: 10/2007

Revised: 06/2020

Policy:

The local agency (LA) shall make every reasonable effort to maintain or reestablish WIC services during periods of emergency or disaster, to continue issuance of benefits to participants. When adverse circumstances persist, the state agency (SA) will assist the LA with coordination efforts.

The LA will be guided by the plan or procedures developed by their parent agency for emergency response and disaster preparedness.

Procedures:

1. If an emergency prevents or limits the LA’s ability to carry out normal clinic operations, the LA should contact their SA technical assistance staff for guidance on how to minimize interruptions to WIC services.
   1. If an emergency or disaster has occurred, the LA shall contact the SA as soon as possible and provide the SA with a LA contact person and phone number. If the LA is unable to contact the SA, the LA should contact the Department of Health and Senior Services, Emergency Response Center (ERC) at 1-800-392-0272.
   2. If the emergency or disaster is localized, the affected LA has primary responsibility to coordinate emergency response efforts. If SA technical assistance is needed, the LA shall contact the SA.
   3. If a situation occurs and the LA must make changes to WIC operations due to the emergency or disaster, the LA must provide the SA with information regarding impact to the surrounding area or community.
   4. If SA services are interrupted or there is a state office closure in Jefferson City due to an emergency situation, the SA will notify the LA by email or telephone. The specific affected services and the approximate length of time for the closure will be noted.
   5. Dependent upon the extent of the emergency or disaster, the SA will contact affected authorized WIC retailers. If the LA is aware of authorized WIC retailers that are affected, LA staff can report the information to the SA.
   6. If a power outage affects the LA site for more than twenty-four hours, the LA should utilize other sites or make arrangements with neighboring agencies to assist with certification of participants and issuing food benefits for the affected local site(s).
2. Certification and Issuance of Food Benefits
   1. If an applicant or participant does not have access to proof of eligibility due to the disaster, refer to policies 8.1.120, 8.1.130, and 8.1.210.
   2. If the LA is experiencing a shortage of competent professional authorities (CPA) to perform certification functions due to the disaster, the LA may be approved to modify the food benefit issuance or certification process.
   3. If the participant has foods that were spoiled or lost due to the emergency or disaster, the LA may issue food benefits to replace foods. Issuance of the replacement food benefits shall be documented in the participant’s folder in the Missouri WIC Information Network System (MOWINS).
   4. If a participant has lost their food instrument, refer to policy 9.1.030.
   5. If retailers are affected by the disaster and infant formula is not readily available, the LA shall assess the need for infant formula and contact the SA for guidance.
      1. If services are disrupted and formula is not available through the normal retailers or pharmacies, the SA will contact the rebate formula manufacturer to have infant formula direct shipped to the LA.
      2. Storage and security of infant formula will be the responsibility of the LA. The LA should work with their parent agency to identify other community entities such as their local Red Cross, schools, etc., for storage of supplies of formula when retailers are unavailable.
3. Breastfeeding
   1. LA staff will encourage mothers to continue breastfeeding their infants during emergency situations.
   2. In the event that formula is unavailable or limited, or cannot be safely prepared, LA staff will encourage and offer assistance to WIC women who had previously weaned to re-lactate or to induce lactation if they have never breastfed.
   3. Basic strategies for re-lactation and induced lactation education should be a cooperative effort by the State WIC Breastfeeding Coordinator, the LA Breastfeeding Coordinator, and the community/area International Board Certified Lactation Consultant (IBCLC).
4. WIC Service Delivery during an Emergency or Disaster
   1. The USDA may grant waiver authority to allow the SA and the LA to continue providing services during an emergency situation.
   2. Flexibilities which are currently authorized in regulation and may be exercised at the discretion of the SA to ensure WIC participants are provided services include the following:
      1. Remote nutrition education may be done on any currently certified participant.
      2. Bloodwork may be deferred for up to 90 days after the date of certification or mid-certification assessment (MCA) if the participant has another qualifying risk factor.
      3. Certification periods may be extended for up to 30 days.
      4. Physical presence requirements (anthropometric data and proof of eligibility must be available) may be waived in the following situations:
         1. Infants under 8 weeks of age for whom all necessary data from birth is provided.
         2. Infants or children present for certification/MCA at least once within the prior 12 months and are under the care of one or more working parents or caretakers whose working status presents a barrier to bringing the infant or child into the LA.
         3. Infants or children present for initial WIC certification and receiving ongoing healthcare.
         4. Applicants, participants, parents, or guardians who have a disability that makes it difficult to come to a clinic for certification/MCA. The applicant or participant may be certified or assessed without being physically present. Only those disabilities that create a current barrier to the physical presence requirement may serve as a basis for an exception. Healthcare provider documentation is required for this exemption.
      5. Electronic proof of income and health data may be accepted by the LA. The means used to transmit data must be secure to protect participant confidentiality.
      6. EWIC cards may be mailed if in-person pick up is not possible.
         
         The SA will inform the LAs in writing if any of the flexibilities above may be implemented. Designation of an emergency or disaster does not automatically put these flexibilities into effect.
   3. Waivers
      1. Waiver authority for any regulatory or policy provision for WIC may be provided by congressional order. States may request individual waivers that are relevant and responsive to their current situation when waiver authority is provided to the USDA.
      2. The SA will provide process documentation to all LAs, retailers, and interested parties to describe implementation of approved waivers.

4.1.070 Social Media Communications and Outreach

Authority:

Issued: 10/2015

Revised:

Policy:

The use of social media can be a powerful way to reach our target audience with strategic and effective messages. Local WIC agencies may choose to use social media (Facebook, Twitter, Pinterest, Pandora, Instagram, Flickr, YouTube, etc.) to provide information to applicants and participants about the Missouri WIC program and to promote WIC services and benefits. Social media sites facilitated by local agency staff must be monitored by designated professional staff in the agency to ensure all content is appropriate. Local agency (LA) staff shall not use their personal social media accounts to represent the local agency or the WIC Program. If utilizing social media, the local WIC agency must develop a policy and procedure for social media usage.

Procedures:

1. Social media sites are considered to be an extension of the LA and may be used to:
   1. Promote WIC services.
   2. Announce upcoming events.
   3. Invite participants to nutrition or prenatal breastfeeding classes or support groups.
   4. Advertise breastfeeding promotion or nutrition events.
   5. Promote the fully breastfeeding food package.
   6. Provide evidence-based breastfeeding and nutrition information and resources.
   7. Help new mothers connect with peer counselors.
   8. Communicate information on WIC approved foods.
   9. Recipes using WIC foods.
   10. Link to state WIC nutrition and breastfeeding resources.
2. Local agency staff shall be responsible for what they write and the messages conveyed to WIC participants.
   1. Local agency staff, including peer counselors, and LA volunteers must follow the Participant Confidentiality Policy 1.01700 and shall not post any WIC participant information.
   2. Only local agency address or phone numbers and agency social media contacts shall be provided through social media.
   3. Local agency social media sites shall be used for WIC and Health Department related business.
   4. All information and website links posted on a social media site shall be evidence-based and in line with information provided by the state WIC Program.
   5. Local agency must designate professional staff to monitor all information posted through social media and have full access to the account. It is critical that any social media be monitored on a frequent basis to ensure information is kept up-to-date and that any inappropriate messages posted by the public are removed as quickly as possible to ensure highest quality information.
   6. All information posted on social media shall be culturally sensitive, professional and communications are in good taste. Messages and content must be appropriate to the intended audience.
   7. Items or information related to religion or politics shall not be posted.
   8. Disparaging remarks about an individual or healthcare provider will not be tolerated and can result in loss of funding.
   9. Social media sites must include “This institution is an equal opportunity provider and employer” statement.
   10. The local agency Facebook page must include a disclaimer that advice from other participants should never replace the advice from medical experts. If they have questions or concerns about their health or their baby’s/child’s well-being, they should always contact their physician or their local WIC office.
   11. Social media shall not be used to advertise or promote specific product brands.
   12. Agency staff shall not counsel participants or answer detailed questions through social media.
   13. Staff should ask when they can contact the participant either by phone or invite the participant into the WIC clinic to discuss in more detail. 
   14. Local agency staff shall not use their personal social media accounts to represent their local WIC agency or Breastfeeding Peer Counseling Program.
   15. It is the responsibility of local agency designated professional staff to ensure that agency employees who are representing their local agency through social media have read and understand the social media policy and consequences for not adhering to policy.
   16. Providing a link to the WIC state website is not required, but is allowed when appropriate. One of the purposes of social media is to reach persons who would not normally look to a government agency website for information/guidance.
3. The local WIC agency must develop a policy and procedure for social media usage. The social media policy must address, but is not limited to the following:
   1. The purpose, goals, objectives and strategies for the social media site.
   2. Approved content for the site(s)
   3. Key roles and responsibilities for contributors, reviewers and administration of the page.
   4. Outline a review schedule - how frequently reviewed and information updated.
   5. The local agency who utilizes social media shall attach their social media policy to the annual Local Agency Plan (LAP) to be approved.
   6. If your agency chooses to allow comments, it is recommended that the local WIC agency add a comments policy. Example:
      
      We welcome you and your comments to the __________ Health Department WIC Facebook page. The purpose of this page is to share and discuss information about the Special Supplemental Nutrition Program for Women, Infants and Children program.
      
      The __________ Health Department WIC reserves the right to remove any comments that are deemed inappropriate or off-topic from the purpose of this page.
      
      Please note that the comments expressed on this site do not reflect the opinions and position of ___________ Health Department WIC or its employees. If you have questions concerning the operation of this online discussion site, please contact ___________.
4. Social media is a digital conversation between people.
   Considerations when using Social Media:
   1. Facebook
      1. A Facebook Page can be set up to provide information to a large number of people. Anyone can like the page. It is not recommended to allow the public to make posts if the page cannot be monitored frequently throughout the day.
      2. A Facebook Group is a private page which make it easy to connect with specific sets of people. This allows for more interaction and discussion. WIC provider designated professional staff must be available to monitor discussions for a Group. Participation must be by invitation and a WIC participant should not be made a member without their knowledge.
      3. It is recommended that local agency staff not to “Friend” WIC participants. In small communities it may be difficult to prevent, but staff should be cautious in becoming a Facebook Friend with a WIC participant on their personal Facebook page.
      4. Post often to keep your audience engaged, but not too often. It is recommended to post no more than one to two times per day. Experts suggest that posts are viewed more during the week than on weekends. Fridays have the least number of views.
      5. Keep messages short, simple, kind and friendly. Pay attention to correct spelling and grammar.
      6. Use acronyms that everyone understands or spell out acronyms that could cause confusion.
      7. People need to get something out of the time they spend with you. Make reading your posts or comments worth their time.
      8. Post Facebook chats, events, quizzes, contests/challenges, questions, videos, photos, widgets and interactive posts and comments to encourage followers to participate in conversations.
   2. Twitter:
      1. Twitter may be used to share information, commentary, descriptions of events, and to highlight online content.
      2. Keep your content short and simple to make it easy for followers to retweet the message without having to edit.
      3. Consider posting weekly at a minimum. 
      4. Consider holding Twitter events to encourage followers to participate in conversations about your priority topics.
   3. Text Messaging:
      1. Text messaging is a simple and easy way to reach a large portion of participants and can include links to other media channels.
      2. Text messages should be short and concise.
      3. Abbreviations should only be used when they are easily understood and do not change the meaning of the message.
      4. Links to traditional web sites should be avoided and links to sites designed specifically for mobile devices should be used.
      5. Texting is a good way to remind participants of their WIC appointments and what to bring.
      6. Short targeted educational messages can be texted to participants and they can be encouraged to contact their local WIC agency if they have more questions. For example, a new breastfeeding mom could be texted “How is breastfeeding going? Call WIC at _________if you have any questions.”
      7. A cell phone is not needed to send a text. If the cell phone carrier of the participant is known, texting can be done by computer using most email programs. See EMAILING/TEXTING CLIENTS instructions.
   4. Online video sharing sites, such as YouTube, Flickr, Google, etc.:
      1. Simple, easy-to-follow “stories” work best, with a single message or call to action.
      2. Use of jargon, technical information, or detailed charts and graphs should be avoided.
      3. Anyone with Internet access can upload, share, view and comment on video footage.
5. Promote your social media sites.
   1. Provide links through your local WIC agency web page.
   2. Provide information on referral lists and other handouts.
   3. Promote in your clinic with signs and word of mouth.
   4. Cross-promote all social media sites to other media channels with similar audiences.

5.1.010 Monthly Administrative Cost Invoice

Authority: 2008 7 CFR 246.13(j); 246.16(d); 246.25(a)

Issued: 10/1990

Revised: 10/2009

Policy:

The local agency (LA) shall use the online WIC invoicing application to complete the Monthly Administrative Cost Invoice to request for reimbursement.

The LA shall submit a monthly reimbursement request for the prior month's expenses, with required documentation, by the 10th of the following month, except in June.

The state agency (SA) reserves the right to deny reimbursements on costs submitted more than 60 days after the due date.

The LA shall be reimbursed not greater than forty percent (40%) of their caseload-based assigned amount in the first quarter, sixty-five percent (65%) in the second quarter and ninety percent (90%) in the third quarter, with the remainder billed in the fourth quarter.

The LA shall use the funds for only the approved activities and materials as budgeted and approved. Changes among budgeted categories shall be requested online and approved prior to expending funds.

The LA shall define on each reimbursement request, the components of operational costs that are related to nutrition education and breastfeeding promotion and support. At a minimum, one sixth (1/6th) of the LA's annual operational reimbursement, excluding special grant(s), must be spent on nutrition education and breastfeeding promotion and support.

Procedures:

1. The monthly administrative cost invoice is used to document:
   1. Expenses for which the LA is requesting reimbursement.
   2. Allowable in-kind costs as authorized by the current fiscal year contract.
2. The LA must submit the monthly administrative cost invoice to the SA via the online WIC Invoicing Application by the close of business on the 10th of each month except June.
   1. The LA will be notified in advance of the June submission date, which will be coordinated with the end of the state fiscal year.
   2. When the 10th of the month falls on a holiday or weekend, the invoice is due the last working day prior to the 10th.
   3. Invoices received after this date may not be paid until the next payment cycle.
3. Upon receipt of the invoice, the state fiscal monitor will do the following:
   1. Review the invoice for accuracy and appropriate completion.
   2. Review the invoice for incorrect billing.
   3. Request changes on the invoice from the LA.
   4. Adjust the invoice to comply with the contract.
   5. Reject the invoice or process the document for payment.
4. The LA may amend a previously submitted invoice by adding or subtracting incorrect costs on next month's administrative cost invoice. Explain the change in the comment area.
5. The LA cannot bill more than 100% of the original allocation in any line item without prior approval from the SA.
   1. When LA wants to bill more than 100% of the original allocation in a line item, the LA must submit a budget adjustment request in the online WIC invoicing application and e-mail the request to their TA team.
   2. Funds allocated for breastfeeding grant or other special grant(s) cannot be reallocated to cover over-expenditures of other line item.
   3. The State WIC technical assistance team must approve the request prior to expending fund.
6. For instructions to complete the Online WIC Invoicing Application, refer to the Online Invoicing Application User Manual.

5.1.020 Line Item: Personnel Compensation

Authority: 2008 7 CFR 246.14(c)

Issued: 01/1981

Revised: 10/2009

Policy:

The local agency (LA) shall include total costs incurred to provide WIC services under the WIC contract for salaries and wages.

The LA shall budget for personnel compensation based on time planned to be used.

The LA shall bill for personnel compensation according to actual time spent by specific individuals each month.

The LA must retain documentation of costs and expenditures billed in this line item.

Procedures:

1. When billing for personnel compensation each month, the LA should use each employee's monthly salary, hourly wage or specific monthly scale.
2. Documentation of costs and expenditures must be retained as follows:
   1. Auditable time accounting or time sheets, signed by the employee, which documents hours and costs incurred for program management, client services, nutrition education, and breastfeeding promotion and support.
   2. Payroll ledgers or other records.
   3. Contracts where applicable.
   4. Pay schedules or wage scales.
   5. Records of actual expenditures such as payroll printouts, check stubs, etc.
3. Program management, client services, nutrition education, and breastfeeding promotion and support costs:
   1. Are allowable on this line item. Refer to 4.1.050.
   2. Each category of costs must be shown and charged by actual time spent by specific individuals each month, based on their time and salary for the month.
4. Lead screening and referral costs:
   1. Allowable personnel time for lead screening and referral include staff time to:
      1. Develop a nutrition care plan.
      2. Provide nutrition education.
      3. Make health care referrals.
      4. Perform hematological tests used for detecting iron-deficiency, such as hemoglobin, hematocrit or free erythrocyte protoporphyrin (EP).
   2. Personnel costs for performing lead screening, such as venous blood lead tests and laboratory analysis of blood samples that are intended for any purpose other than to assess iron status, are not allowable WIC costs.
5. Immunization screening and referral costs:
   1. Allowable personnel costs for immunization screening and referral include staff time to:
      1. Screen immunization records.
      2. Make health care referrals
      3. Schedule appointments for immunizations.
   2. Personnel costs for providing immunizations are NOT allowable WIC costs.

5.1.030 Line Item: Personnel Benefits

Authority: 2008 7 CFR 246.14(c)

Issued: 01/1981

Revised: 10/2009

Policy:

The local agency (LA) shall include employee fringe benefits costs paid by the agency on the personnel benefits line item when budgeting and billing.

The LA shall bill for personnel benefits accordingly to the actual benefits for each employee based on the employee's actual WIC time and salary.

The LA must retain documentation of costs and expenditures billed in this line item.

Procedures:

1. Benefits that may be charged to the WIC contract include:
   1. Employer's share of FICA taxes.
   2. Employer's contribution to health and life insurance for employees.
   3. Worker's compensation.
   4. Unemployment Compensation Insurance.
   5. Employer's share of employee's pension plan.
   6. Other benefits as approved by the state WIC program/office.
2. The following cannot be charged to the personnel benefits line item:
   1. Leave and holiday time.
   2. Liability insurance.
   3. Bonding insurance.
   4. Employee's contribution to benefits.
3. The LA may budget for personnel benefits based on any combination of the following:
   1. An overall portion of salaries.
   2. A specific portion of salaries for each individual.
   3. The WIC portion of lump sum amounts for specific benefits.
4. Documentation of costs and expenditures must be retained as follows:
   1. Auditable time accounting or time sheets, which also show nutrition education time spent.
   2. Benefits and payroll ledgers or other records.
   3. Contracts, invoices or other documents proving benefits provided.
   4. Records of actual expenditures such as check stubs, canceled checks, receipts, etc.
5. Program management, client services, nutrition education, and breastfeeding promotion and support costs:
   1. Are allowable on this line item.
   2. Must be shown and charged according to actual benefits for each employee based on the time and salary for the month.

5.1.040 Line Item: Contract Services

Authority: 2008 7 CFR 246.14(c)

Issued: 02/1989

Revised: 10/2009

Policy:

The local agency (LA) shall use the contract services line item to budget and bill allowable expenses for contracts with other agencies or with individuals providing nutrition services and/or interpretive services.

Procedures:

1. When budgeting and billing, the local agency shall include, on the contract services line item, money paid through contracts with:
   1. Other agencies or companies (sub-contractors) or individuals for:
      1. Deliverables such as certifications.
      2. Services such as nutrition services and/or peer counseling services.
      3. Services for interpretation, such as hearing-impaired and non-English.
   2. Individuals for allowable services outside the scope of usual clinic operations, such as interpretive services for hearing-impaired or non-English or peer counseling services.
2. The LA and the subcontractor shall determine the amount of fees and the services to be provided. The state agency should be consulted if necessary.
3. The LA shall bill for contract services costs by whichever of the following methods is applicable:
   1. Multiplying the established fee by the deliverables provided in that month.
   2. Based on hours worked and/or services provided.
   3. Based on other documentation approved by the agency and submitted by the subcontractor.
4. Documentation of costs and expenditures must be retained as follows:
   1. A signed contract between the LA and the subcontractor or individual that has been approved during the annual Local Agency Plan budgeting process. The contract shall include:
      1. The amount of fees to be paid.
      2. The services or deliverables to be rendered for the fees.
      3. The time period of the contract, to be the current fiscal year or less.
   2. Documentation of payment to the subcontractor or individual.
   3. Subcontractor or individual records submitted for services performed.
5. Nutrition education costs are allowable on this line item based on services related to direct nutrition education counseling, including breastfeeding peer counseling.

5.1.050 Line Item: Conference and Training

Authority: 2008 7 CFR 246.14(c)

Issued: 01/1981

Revised: 10/2009

Policy:

The local agency (LA) shall budget and bill all non-personnel costs for approved conferences and trainings on the conference and training line item.

Personnel costs associated with conference and training shall be shown in the line items for personnel compensation and benefits.

Nutrition contractor costs associated with conference and training shall be shown in the line item for contract services.

Procedures:

1. Conference and training operational costs may be budgeted and billed for:
   1. The WIC Conference. Specific costs projected for the WIC Conference will be included with the materials sent for the local agency plan (LAP).
   2. Other approved non-WIC training programs.
   3. WIC trainings and in-services.
   4. Approval from appropriate member of the state WIC staff, dependent on job function of trainee, i.e. nutrition training not originally submitted in the LAP.
2. Allowable costs under this line item include any of the following:
   1. Travel.
   2. Lodging if greater than 50 miles or more from the official LA main office.
   3. Meals except for training conducted within an agency for their staff.
   4. Registration fees.
3. Documentation of costs and expenditures must be retained as follows:
   1. Receipts for:
      1. Lodging.
      2. Registration fees.
      3. Travel other than by automobile.
   2. An expense sheet or comparable record, signed by the employee, for both:
      1. Meals.
      2. Mileage.
         
         Note: Mileage shall be reimbursed at the lower of the current IRS rate for mileage reimbursement or the mileage reimbursement rate set by the LA's internal policy.
   3. Agency direct payment of employee expenses or reimbursement to the employee.
4. Nutrition education costs are allowable on this line item:
   1. For any individual responsible for any percentage of nutrition education.
   2. At 100% of the costs.

5.1.060 Line Item: Travel

Authority: 2008 7 CFR 246.14(c)

Issued: 01/1981

Revised: 10/2009

Policy:

The local agency (LA) shall budget and bill all travel for WIC operations, except for conference and training related, on the travel line item.

Procedures:

1. Travel for WIC operations may be for any of the following:
   1. Satellite clinic sites.
   2. Vendor activities.
   3. Outreach activities.
   4. Special administrative activities associated solely with WIC.
   5. Non-training meetings sponsored by WIC.
   6. Home visits by peer counselors to assist women to continue breastfeeding.
2. Allowable costs under this line item include any of the following:
   1. Travel.
   2. Lodging if greater than 50 miles or more from the official LA main office.
   3. Meals.
3. Documentation of costs and expenditures must be retained as follows:
   1. Receipts for:
      1. Lodging.
      2. Travel other than by automobile.
   2. An expense sheet or comparable record, signed by the employee, for:
      1. Meals.
      2. Mileage.
         
         Note: Mileage shall be reimbursed at the lower of the current IRS rate for mileage reimbursement or the mileage reimbursement rate set by the LA's internal policy.
   3. Agency direct payment of employee expenses or reimbursement to the employees.
4. Nutrition education costs are allowable on this line item if the cost for travel is directly applicable to nutrition education, including breastfeeding promotion.

5.1.070 Line Item: Equipment Purchases

Effective: 06/2025

Issued: 10/2009

Authority references: 2024 2 CFR 200.302(b)(3); 7 CFR 246.14(c), 246.24(a), 246.25(a)(1), WIC policy memo 95-5, WIC policy memo 98-3; FNS Instr. 815-1

Policy:

The local agency (LA) shall budget and bill for equipment purchases, including all health assessment equipment, on the equipment purchases line item. This excludes computer hardware and software.

Procedures:

1. Processing purchase requests.
   1. Purchase requests may be processed during the local agency plan (LAP) if equipment is planned or at another time during the year if equipment is needed.
      1. The request must justify why the equipment is needed and must be reasonable, allocable and necessary.
   2. Purchase requests approved in the LAP only approve the allocation of funds for the purchase within the LA budget. The following purchase requests require written authorization prior to purchasing:
      1. Equipment valued at $300 or more per item.
      2. Health assessment equipment regardless of value.
      3. Equipment to be purchased with Breastfeeding Peer Counseling Program funds regardless of value.
   3. The SA will review the request and approve, deny or make changes based on the following:
      1. Need and appropriateness of equipment.
      2. Cost.
      3. Status of the LA budget.
      4. Overall financial status of the WIC program.
2. Purchase request authorization.
   1. Purchase request authorization will specify the type of equipment approved to purchase and the maximum allowable cost.
   2. The LA must use the Request for Authorization to Purchase form.
3. Sharing equipment costs.
   1. Equipment may be charged fully or partially to WIC.
      1. A cost allocation plan must be included in the purchase request.
      2. Include receipts, schedules or other source documents for all expenses.
      3. Include formulas used for calculating costs and the following:
         1. Documentation of the basis of the formula.
         2. The actual calculated costs.
4. Equipment purchases line item.
   1. The LA shall bill for reimbursement on the equipment purchases line item in WebGrants after purchase.
   2. Documentation of costs and expenditures must be retained and include the following:
      1. Purchase invoice and/or receipt.
      2. Authorization letter from the SA.
      3. Verification of payment.
      4. Updated inventory record.
         1. Refer to policy 3.1.010 for equipment inventory procedures.
   3. Nutrition education costs are allowable on the equipment line item if the equipment is used for nutrition education and approved by the SA.
      1. Electric breast pumps are included in this category.

5.1.080 Line Item: Nutrition and Breastfeeding Materials

Effective: 06/2025

Issued: 01/1981

Authority references: 2025 7 CFR 246.14(c)(1)(i-iv); 246.2; 2016 FNS Breastfeeding Policy and Guidance; 95-5; 95-10; 2003-07; FNS-I 815-1-P

Policy:

The local agency (LA) must budget and bill all materials and supplies used to directly support nutrition and breastfeeding education, including breastfeeding support aids and accessories, on the nutrition and breastfeeding materials line item.

Breastfeeding aids and accessories may not be issued to pregnant women unless the pregnant woman is currently breastfeeding a participating WIC infant or child.

The LA must obtain prior purchase approval from the state agency (SA).

Procedures:

1. The following items are allowable on the nutrition and breastfeeding materials line item:
   1. Items for food demonstrations or cooking classes such as food, pans, cooking utensils and cleaning supplies.
   2. Printed and electronic materials (e.g., handouts, videos, DVDs and PowerPoint presentations). Refer to policy 2.4.100.
   3. Resource materials such as peer-reviewed nutrition and breastfeeding books, magazines, journals and newsletters.
   4. Teaching aids such as flip charts, DVD players, projectors, easels, markers, food models, fruit and vegetable sets, educational games, breastfeeding dolls, breast models and other educational props.
   5. Breastfeeding aids that directly support breastfeeding, such as breast pumps, pumping kits, flanges or inserts for flanges, nipple shields and supplemental nursing systems.
      1. Nipple shields and supplemental nursing systems can only be issued under the management of an International Board Certified Lactation Consultant (IBCLC).
   6. Breastfeeding accessories that facilitate breastfeeding, such as milk collectors, breast shells, hot and cold therapy packs, reusable sterilizing bags for pump kits, nursing pads and breast milk storage bags. When considering the purchase of accessories, the benefits of providing such accessories, which provide less direct support for the initiation and continuation of breastfeeding, should be weighed against the importance of breastfeeding management functions and participant benefits that otherwise could be provided.
   7. Other allowable breastfeeding accessories for clinic use only, not for distribution to participants, include breastfeeding or standard pillows with impermeable covers, disposable covers for the pillow and reusable, cleanable nipple rulers that participants can use to measure themselves for flange fitting.
2. The following program incentive items are allowable but must be provided with nutrition and breastfeeding education. The cost must be reasonable and necessary and not exceed ten dollars. When feasible, a WIC-specific educational message should be printed on the item.
   1. Fit WIC activity items such as jump ropes, hula hoops, frisbees, pedometers, playing or exercise balls and exercise videos.
   2. Kitchen tools, vegetable seeds, digital timers, cookbooks, divided plates, baby utensils and drinking cups (approved type for children up to 2 years of age).
   3. Reusable bags, refrigerator magnets and promotional buttons.
   4. Blankets, bibs, onesies and shirts for fully and mostly breastfeeding infants.
3. Due to cost, the following items may be allowable with special consideration from the SA:
   1. T-shirts for staff for promotional events such as World Breastfeeding Week and National Nutrition Month.
      1. The LA must print t-shirts with the WIC and/or WIC Breastfeeding Support logos.
   2. Breast milk storage coolers and nursing cover-ups for fully and mostly breastfeeding women.
   3. Helium tanks and balloons for nutrition and breastfeeding education and promotion events.
   4. Rugs printed with information or graphics that have a clear and useful connection to nutrition or breastfeeding education.
      1. Rugs and other décor without a nutrition or breastfeeding message may be allowable per policy 5.1.090.
   5. Nursing bras, with approval from the state breastfeeding coordinator.
4. The following items are not allowable on the nutrition and breastfeeding materials line item:
   1. Breastfeeding aids that do not directly support the initiation and continuation of breastfeeding, including, but not limited to, infant pillows given to participants, nursing blouses, diaper bags, nursing bracelets, breastfeeding pump bustiers or nursing slings and breast milk or baby food storage trays or other storage containers. Companies may donate these items to the LA, but the donation cannot be applied to the breastfeeding spending target or nutrition education expenditure.
   2. Breastfeeding aids used to treat sore nipples, such as lanolin, nipple ointments, hydrogel pads or other gel pads.
   3. Bottles, pacifiers or nipple everters.
   4. Pens, lanyards, wristbands and jewelry.
   5. Galactagogues, supplements or functional foods intended to treat low milk supply may not be accepted as donations.
5. The LA must consult with a member of the SA staff for verification before budgeting or billing other costs that seem to apply to this line.
6. Documentation of costs and expenditures must be retained as follows:
   1. Receipts or other source documents.
   2. Auditable documentation of payment.
   3. Approval from the SA through the local agency plan (LAP) process or other times throughout the year, as necessary.
7. The SA will review this line item throughout the year to verify appropriate usage.
8. The SA will determine if money in the nutrition materials line item has been spent according to the LAP. If it has not been spent as outlined in the plan, the LA will submit alternate requests for using the money.
9. If the plan of action for alternate requests is not approved in WebGrants, the dollar amount in question may be reallocated upon request by the LA and approval by the SA. If the reallocation request is not approved, the funds cannot be used for any purpose other than nutrition and breastfeeding education materials.
10. All costs under this line item are nutrition or breastfeeding education allowable.

5.1.090 Line Item: Administrative Office Costs

Authority: 2008 7 CFR 246.14(c)(4) & MPSF-1:WC-94-33-P

Issued: 01/1981

Revised: 10/2009

Policy:

The local agency (LA) shall budget and bill costs that do not fall into another specific category on the administrative office costs line item.

Procedures:

1. The local agency may include any of the following administrative office costs on the administrative office costs line item when budgeting and billing:
   1. Postage, UPS, delivery, freight, handling, etc.
   2. Office supplies, including computer paper, printer ribbons, small parts and nutrition aids such as poster board, markers, lettering, etc.
   3. Communication costs (telephone, fax, etc.).
   4. Equipment rental or repair.
   5. Printing and reproduction costs.
   6. Costs of advertisements for staff recruitment.
   7. CLIA registration fees.
   8. Dues for professional associations.
   9. Insurance and service fees for supplying breast pumps.
   10. Small appliances used as nutrition aids.
2. If a local agency has other costs that seem to be applicable to this line item, it should consult with the state agency for verification before budgeting or billing.
3. The local agency shall bill for administrative office costs according to one of the following methods. The method the local agency chooses to use shall be described in the budget portion of the local agency plan for approval by state WIC staff.
   1. Actual costs that are incurred separately for WIC.
   2. A percentage of the total costs:
      1. Based on the total personnel hours spent on WIC compared to the total local agency hours.
      2. Documented by a verifiable time accounting system.
   3. An alternative method submitted with the local agency plan and subsequently approved by state WIC staff.
   4. A combination of the above methods may be used for different types of costs within this line item.
4. Documentation of costs and expenditures must be retained as follows:
   1. Receipts or other source documents for all purchases and expenditures.
   2. Formulas used for calculating costs as well as:
      1. The documentation of the basis of the formula.
      2. The actual calculated costs.
   3. Auditable documentation of payment.
5. Nutrition education costs allowable on this line are costs for printing and reproduction, insurance and service fees for supplying breast pumps, office supplies, small appliances used for nutrition education, and some computer software (with approval of the state agency).

5.1.100 Line Item: Medical Materials

Authority: 2008 7 CFR 246.14(c)(2)(ii)

Issued: 02/1989

Revised: 10/2009

Policy:

The local agency (LA) shall budget and bill items needed to do health assessments on the medical materials line item.

Procedures:

1. The local agency shall include the costs of expendable medical supplies used for WIC health assessments on the medical materials line item when budgeting and billing.
2. The local agency shall not budget or bill the cost of medical materials supplied directly from the State agency.
3. The local agency may budget and bill for medical materials according to any of the following methods:
   1. Actual costs that are incurred separately for WIC.
   2. A percentage of the total cost of supplies used in WIC and other programs:
      1. Based on the total personnel hours spent on WIC compared to the total local agency hours.
      2. Documented by a verifiable time accounting system.
      3. This method shall not be used if a disproportionate share of medical supplies are used in other programs.
   3. A combination of the above methods may be used for different supplies within this line item.
4. Documentation of costs and expenditures must be retained as follows:
   1. Receipts or other source documents for all purchases and expenditures.
   2. Formulas used for calculating costs including:
      1. The documentation of the basis of the formula.
      2. The actual calculated costs.
   3. Auditable documentation of payment.
5. Nutrition education costs are not allowable on this line item.
6. Lead screening and referral costs:
   1. Allowable medical costs include medical supplies associated with performing hematological tests used for detecting iron-deficiency, such as hemoglobin, hematocrit or free erythrocyte protoporphyrin (EP).
   2. Medical costs for lead screening, such as venous blood tests and laboratory analysis of blood samples that are intended for any purpose other than to assess iron status, are not allowable WIC costs.
7. Medical costs for immunizations, such as vaccine and supply costs, are not allowable WIC costs.

5.1.110 Line Item: Computer Hardware/Software

Authority: 2008 7 CFR 246.14(d) & FNS Instr. 808-1, 815-1

Issued: 11/1991

Revised: 10/2009

Policy:

The local agency (LA) shall budget and bill all purchases of computer hardware and software on the Computer Hardware/Software line item. The LA must obtain prior purchase approval from the state WIC program.

Procedures:

1. The local agency must request written authorization for the purchase of computer hardware equipment or software. When authorization is given, it will specify both:
   1. The piece(s) of equipment approved. This will include specifications recommended for the equipment to work with the system.
   2. The software should be identified and the location of the computer where it will be installed.
   3. The maximum allowable cost.
2. Upon receipt of the authorization, the local agency shall follow local purchasing guidelines and specifications necessary in the purchase authorization.
3. After purchase, the local agency will bill for reimbursement on the Computer Hardware/Software line item. The state agency will reimburse the local agency for the purchase only if the following are listed in the comment section of the On-line Monthly Administrative Cost Invoice:
   1. Item purchased (i.e., monitor, PC, printer, etc.)
   2. Manufacturer name (i.e., IBM, Samsung, etc.)
   3. Serial Number
   4. Model Type or Number
   5. Where equipment is to be housed (i.e., satellite site)
   6. Date the equipment was purchased
4. The state agency will send the WIC inventory tag to the local agency. The tag must be immediately placed on the equipment purchased. If a number of pieces of equipment are purchased, each tag will indicate the piece to which it shall be attached.
5. Documentation of costs and expenditures must be retained as follows:
   1. Purchase invoice and/or receipt.
   2. Authorization letter.
   3. Verification of payment.
   4. Updated inventory record.
6. Nutrition education costs are not allowable on this line item.

5.1.120 Line Item: Facilities Costs

Authority: 2008 7 CFR 246.14(a)(1) & FNS Instr. 808-1

Issued: 01/1981

Revised: 10/2009

Policy:

The local agency (LA) shall budget and bill allowable space and utilities costs on the facilities costs line item.

Procedures:

1. Facilities costs for a local agency's primary site are not allowable unless both of the following conditions are met:
   1. Costs must be approved by the state agency.
   2. Costs must be equitably shared by all programs utilizing the local agency's facility.
2. Satellite site facilities costs may be budgeted and billed on the facilities costs line item. However, if the satellite site offers other programs, the costs must be equitably shared by all programs utilizing the satellite site facility.
3. When approved, utilities and space utilization costs may be budgeted and billed on the facilities costs line item. Facilities costs may include:
   1. Utilities.
   2. Building maintenance and repair costs which neither add to the permanent value of the property nor appreciably prolong its intended life but keep it in efficient operating condition.
   3. Rent.
   4. Depreciation or use allowance on facilities owned by the local agency.
4. When approved, these costs may be billed as follows:
   1. Utilities, maintenance, and/or rent, based on one of the following methods:
      1. Total costs for areas used exclusively for WIC.
      2. A proportionate cost based on the percentage of floor space used exclusively by WIC.
      3. A proportionate cost based on the percentage of personnel time spent on WIC in relation to the total hours for the local agency.
      4. An alternate method agreed to by the state agency and the local agency.
   2. Depreciation or use allowance:
      1. must use an auditable, approved method for prorating depreciation.
      2. must be calculated by one of the following methods.
         1. A proportionate cost based on the percentage of floor space used exclusively by WIC.
         2. A proportionate cost based on the percentage of personnel time spent on WIC in relation to the total hours for the local agency.
      3. Use allowance must be proportionate to WIC's use, but may never exceed an annual rate of 20% of the building's acquisition cost.
5. Documentation of costs and expenditures must be retained as follows:
   1. Receipts, schedules or other source documents for all expenses.
   2. Formulas used for calculating costs as well as:
      1. The documentation of the basis of the formula.
      2. The actual calculated costs.
   3. Approvals by state WIC staff.
   4. Auditable documentation of payment.
6. Nutrition education costs are not allowable on this line item.

5.1.130 Line Item: Indirect Costs

Authority: 2 CFR Part 200 Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Awards Subpart E – Cost Principles §200.416; Appendix V to Part 200—State/Local Government and Indian Tribe-Wide Central Service Cost Allocation Plans; Appendix VII to Part 200—States and Local Government and Indian Tribe Indirect Cost Proposals

Issued: 01/1981

Revised: 10/2015

Policy:

A claim for indirect costs shall be supported by either a federally approved indirect cost rate letter or an approved cost allocation plan.

Indirect cost billing shall not exceed the federally negotiated indirect cost rate or the de minimis rate up to 10%.

Cost must not be allocated as an indirect cost if any other cost incurred for the same purpose, in like circumstance, has been assigned as a direct cost.

Procedures:

1. Indirect costs are those costs incurred for a common or joint purpose (i.e., County Health Dept.) benefitting more than one cost objective (or program – i.e., Immunizations, WIC, Head Start, Medicaid, Social Services, and Health Dept.,), and not readily assignable to the cost objectives specifically benefitted, without effort disproportionate to the results achieved, such as utilities, rent, administrative costs, accounting, HR/personnel service costs, and building maintenance.
2. The local agency (LA) may claim indirect costs in one of two ways.
   1. An indirect cost rate may be established with a rate approval letter from the federal agency (such as the U.S. Department of Health and Human Services (HHS)) to the LA.
   2. The LA is entitled to a de minimis indirect cost rate up to 10% of the modified total direct costs (MTDC).
      1. MTDC means all direct salaries and wages, applicable fringe benefits, materials and supplies, services, travel, and up to the first $25,000 of each contract. MTDC excludes equipment, capital expenditures, rental costs, tuition remission, scholarships and fellowships, and the portion of each contract in excess of $25,000. 2 CFR Part 200.68 Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Awards
3. In lieu of using the de minimis rate of 10%, the contractor may opt to accept an indirect cost rate lower than 10% of the modified total direct costs or the contractor may waive charging indirect costs.
4. The LA must budget and bill indirect costs to all other federal programs operated by the business entity associated with the LA to be eligible for WIC reimbursement on this line item.
5. Documentation of costs and expenditures must be retained as follows:
   1. The rate approval letter from HHS (if applicable).
   2. Auditable documentation of actual expenses covered under indirect costs.
6. No portion of the indirect cost line item is chargeable to nutrition education.
7. All expenses must be charged consistently either as direct or indirect, further no expense can be double charged under both direct and indirect.
8. If the total costs to deliver services at the LA exceed the statewide allowable unit cost, the LA should show the indirect costs in the in-kind services part of the budget proposal; however, Indirect Costs shall only be billed at the federally negotiated indirect rate or up to 10% de minimis in accordance with the original budget.

5.1.140 Line Item: Special Funds

Authority: 2008 7 CFR 246.11(c)(1)&(2), MPSF-1: WC-91-16-P, Loving Support Breastfeeding Peer Counseling Grant Guidance

Issued: 10/1990

Revised: 10/2009

Policy:

The local agency (LA) shall bill all costs incurred for special project(s) on the appropriate individual Special Fund line item of the Online WIC Invoicing Application.

Detail of the costs billed, shall be submitted on the individual Special Fund invoice tab of the Online WIC Invoicing Application.

Procedures:

1. The LA may receive special project funds through an application submitted to and approved by the state agency.
2. As these funds are specially designated, they must be:
   1. Used for the project exclusively.
   2. Tracked separately from other costs.
3. For Breastfeeding Peer Counseling allowable expenditures, refer to "Guidelines for Allowable Items for Reimbursement for Breastfeeding Peer Counseling Project(s)" in the Breastfeeding Peer Counseling Training Manual.
4. Other special projects shall be budgeted and billed according to the approved contract between the State agency and the LA, and detailed instructions from the state agency.
5. The LA shall bill for special projects as follows:
   1. Report expenditures for allowable items on the Online WIC Invoicing Application tab under the applicable Special Funds, i.e. WIC Breastfeeding Peer Counseling Project(s), Outreach Enhancement Project, etc. Reimbursement will be based on this online invoice.
   2. The costs must be billed monthly.
   3. When documenting costs for personnel compensation and benefits, it must detail:
      1. Names and titles.
      2. Hours worked.
      3. Salary and benefits value.
   4. Description of non-personnel compensation costs items must be detailed in the "Remarks" section on the individual special fund invoice. Examples of nonpersonnel compensation cost items are office supplies, conference and training, travel, etc.
6. Documentation of costs and expenditures must be retained as follows:
   1. Auditable personnel compensation and benefits records as defined in the 5.1.020 and 5.1.030.
   2. Other source documentation as applicable to the specific project line item. Refer to 5.1.040 and 5.1.090.
   3. The LA shall enter the title of the specific project on any source documentation related to special funds.
7. Special funds awarded for Breastfeeding Promotion should have amounts charged in both the "Actual Operational Costs" and the "Nutrition Education Portion columns of the invoice. Special funds awarded for other project, e.g. Outreach, may have chargeable amounts in the "Nutrition Education Portion" column based on the approved budget.

5.1.150 In-Kind Costs

Authority: 2008 7 CFR 246.16(d)(2)

Issued: 11/1991

Revised: 10/2009

Policy:

The local agency (LA) shall show in-kind costs not reimbursable through available funding in the WIC contract on both the WIC budget and billings. Refer to 4.1.050.

Procedures:

1. A local agency shall show in-kind services in the budget proposal for informational purposes only. In-kind services must be allowable, applicable and documentable.
2. A local agency shall show in-kind services on the monthly Online WIC Invoicing Application Invoice (WIC-24) although they will not be reimbursed.
3. Documentation of in-kind costs and expenditures must be retained as appropriate to the line item.
4. Nutrition education costs may be included in in-kind services as appropriate to the line item.

5.1.160 Local agency Outside Contracting

Authority: 2008 7 CFR 246.4(a)(25), 246.6(d)&(f)

Issued: 10/1990

Revised: 10/2009

Policy:

The local agency (LA) may enter into contracts or agreements with individuals, other local agencies, or other entities to provide WIC services. The contracts or agreements must include specifics as detailed in the procedures below.

Procedures:

1. The LA may contract with an individual to provide staff functions. When this is done, the agency shall assure that:
   1. The individual meets the requirements for the specific position he/she will fill.
   2. The contract includes, at a minimum, the following items:
      1. Amount of monetary compensation including all of the following:
         1. Hourly rate.
         2. Fringe benefits, if any.
         3. Salary increases to be expected, if any.
      2. Clearly written job responsibilities.
      3. Amount of time the position will be needed monthly.
      4. For a nutritionist, a total of one day per month (approximately) should be set aside for the following responsibilities:
         1. Planning for nutrition education,
         2. Continuing education (in-services, conferences, etc.),
         3. Consultation with state WIC staff, and
         4. Development and evaluation of the nutrition portion of local agency plan.
      5. Probationary period, if applicable.
      6. Performance reviews.
      7. Expenses to be reimbursed. Mileage may be charged to WIC if approved by the state agency and reimbursed at the local agency rate.
2. The LA may contract with other local agencies to provide services requiring a nutritionist. When this is done:
   1. One agency must assume the administrative responsibility for the nutritionist.
   2. The administrative agency will contract with the other local agencies that will be sharing the nutritionist's time. That contract should include all of the following:
      1. How many hours will be spent at which location.
      2. How the nutritionist will be paid using one of the following options:
         1. Each agency will pay the administrative agency for the cost of the nutritionist's actual time spent at the agency.
         2. Each agency will pay the nutritionist directly according to the time spent in the agency. With this option, how costs for conferences and in-services will be covered must be included.
      3. The amount and timing of salary increases, if any.
      4. How travel expenses incurred by the nutritionist will be handled. (See A.2.g. above.)
      5. How performance evaluations will be conducted.
      6. How disciplinary actions will be handled.
      7. Termination procedures for terminating the contract with the nutritionist or the other local agency(s) within the contract period, if needed.
3. The LA may use facilities that are not LA owned to deliver WIC services (e.g. Satellite sites).
   1. When this is done, the LA shall contract or develop an agreement with the owner of that facility.
   2. The contract shall specify:
      1. The responsibility of each agency regarding use, cleanliness, insurance, etc.
      2. The monetary compensation, if any, which the contracting entity will receive.
      3. The days and time when the facility will be available to the LA.
      4. The notice that will be given by either party before cancellation of the contract/agreement.
      5. Other items considered necessary.
4. The LA may contract for interpretive services. The LA may specify that the services will be on an as needed basis.
5. Preventing Conflict of Interest
   1. Health professional staff that certifies a WIC applicant/participant for benefits should not on a regular basis, issue food instruments for the same applicant/participant throughout the entire certification period. Refer to 8.1.030.
   2. No one local agency staff or contractor of local agency shall certify oneself for WIC benefits nor issue food instruments or supplemental foods to oneself.
   3. Employees of a local agency and contractor(s) of a local agency shall not certify relatives or close friends for WIC benefits nor issue food instruments or supplemental foods to relatives or close friends.
6. All contracts shall be retained for audit.

5.1.170 WIC Program Income

Authority: CFR 246.15(b); CFR 246.14(a)(2); MPSF-1: WIC-96-13-P; MPSF: WC-99-07-P; P.L. 105-336, Section 203(d)

Issued: 10/1999

Revised: 10/2007

Policy:

WIC program income will be used appropriately to meet the needs of the WIC program. Program funds may not be used to pay for retroactive benefits.

Procedures:

1. Program income is defined as gross income received by the State agency directly generated by a grant-supported activity during the grant period 7 CFR3016.25(b). The following types of funds are program income:
   1. Royalties from publications.
   2. Fees for reproducing or mailing publications, videotapes, posters, etc.
   3. Interest earned on rebate funds for infant formula or other foods.
   4. General grants not tied directly to foods redeemed, but made for inclusion of food items in a State's food package (such as Welch's grants).
   5. Vendor civil money penalties or fines, to also include any interest charged in their collection.
2. WIC program income will be used only to support the goals of the WIC program. Prior approval will be obtained from FNS to use program income for costs that support program objectives but are not currently permissible as charges to the WIC grant. In no event, however, will program income be used for costs specifically disallowed by OMB Circular A-87.
3. WIC program income can be used as any of the following, depending on the needs of the program.
   1. WIC food dollars (100%).
   2. WIC nutrition services and administrative dollars (100%).
   3. Both WIC food and nutrition services and administrative dollars in any combination.
   4. Farmers' Market Nutrition Program (FMNP) matching funds when needed and as allowed by law and regulations.
4. The WIC State director will determine how WIC program income will be used at the end of each quarter. Documentation of use will be maintained and provided to FNS through routine reporting procedures.
5. WIC program income will be used during the fiscal year:
   1. In which the claim arises
   2. In which the funds are collected; and/or
   3. Following the fiscal year in which the funds are collected.

7.1.010 Outreach and Missouri WIC Logo

Authority: 2008 7 CFR 246.4(a)(7, 20), CFR 246.14(c)(3), 7 CFR 246.6(f), WIC Policy Memorandum #95-5: Allowability of Costs for Program Incentive Items

Issued: 01/1981

Revised: 10/2022

Policy:

The local agency (LA) shall have a written outreach plan appropriate to the population within the LA service area. The plan must include demographics for the area served and identify areas of potential need in the WIC-eligible population.

The LA shall have an active outreach and referral network within its service area that includes agencies and organizations which serve populations similar to WIC. The network must include the local Department of Social Services Family Support Division office. The LA will annually contact these community partners to provide updates about WIC, ensure the partner has the correct contact information to facilitate referrals to WIC and ask if the partner needs any additional WIC handouts or other information.

The LA shall update the outreach and referral network information at least annually to maintain accuracy.

The LA shall spend a minimum of 1% of their total FFY budget on WIC outreach.

The LA shall receive design and funding approval from the SA before purchasing any resources or printing materials. Approval of the outreach plan in the LAP does not include design approval unless the design is included in the LAP.

LAs operating in a hospital shall have a cooperative arrangement with the hospital that includes the permission to advise potentially eligible individuals that receive inpatient or outpatient prenatal, maternity or postpartum services or that accompany a child under the age of 5 who receives well-child services, of the availability of program services.

The nondiscrimination statement is required for all printed outreach materials. Refer to policy 11.1.020.

The LA shall use the Missouri WIC logo, provided by the WIC state agency (SA), on all resources (e.g., outreach or retention items, printed materials, signage, websites) paid for with WIC funds. 

Procedures:

1. Creating the LA outreach and referral network.
   1. The network shall include the local Department of Social Services Family Support Division office.
   2. The network shall include other community agencies or organizations that serve similar populations.
   3. The network shall include other organizations and groups considered appropriate by the LA, such as local physicians, schools, religious organizations.
   4. The LA may request the SA to provide guidance and materials to assist with their outreach efforts.
2. Providing community partners with up-to-date materials:
   1. Materials shall describe program benefits, potentially eligible participants and include the name, address, phone number, website or email address of the LA.
   2. Materials shall include the Missouri WIC logo.
   3. The nondiscrimination statement is required for all printed outreach materials. Refer to policy 11.1.020.
      1. Some outreach items may not have room for the statement, for instance, giveaway items like milk cups.
      2. Outreach resources must have the Missouri WIC logo and LA contact number, at a minimum.
         1. With smaller items, the LA name plus WIC or just WIC can be substituted for the logo.
3. Outreach targeting:
   1. Outreach should target all eligible individuals.
   2. The LA shall use US Census, WIC management reports, WIC MICA data, community resources, geo-maps and other data bases.
   3. The LA may consult with the SA to ensure an appropriate target population and adequate methods.
4. Funding:
   1. The LA shall request funding in the local agency plan (LAP).
   2. The LA shall charge the costs of conducting outreach in the following LAP locations.
      1. Personnel compensation of conducting outreach activities shall be included in program management hours. Refer to policy 5.1.020 and 5.1.030.
      2. Travel for outreach activities shall be labeled as outreach. Refer to policy 5.1.060.
      3. All other costs associated with outreach activities shall be listed under administrative office costs in the LAP. Each activity should be entered as individual line items to help with invoicing purposes. Refer to policy 5.1.090.
   3. Additional funding, when available, may be used for special outreach initiatives as appropriate and approved in the LAP. Refer to policy 5.1.140.
5. Documenting Outreach:
   1. The LA shall provide a detailed outreach plan in the LAP.
      1. The plan shall be completed on the outreach plan template provided by the SA.
   2. The LA shall keep a file of all outreach materials used and document the completed activities on the outreach plan template in the fields provided. These shall be retained at the LA for monitoring and compliance verification.
      1. Monitoring and compliance verification shall be conducted throughout the FFY.
6. Missouri WIC Logo:
   1. Items purchased with WIC funds: If LAs choose to include a logo on resources (e.g., outreach or retention items, printed materials, signage, websites) purchased using WIC funds, they must prominently use the current MO WIC logo. The item may have an individualized LA WIC logo as well, but the Missouri WIC logo must be prominently displayed. If there is not room for multiple logos, the Missouri WIC logo must be selected for printing. Prominent use of the Missouri WIC logo means that the Missouri WIC logo will be printed at least the same size as an individualized WIC LA logo.
   2. Items purchased with OTHER funds: If LAs are not using WIC funds for resources (e.g., outreach or retention items, printed materials, signage, websites), they may use an individualized LA WIC logo with or without the Missouri WIC logo.
   3. Items previously printed with individualized LA logos: If an LA has resources (e.g., outreach or retention items, printed materials, signage) without a prominent Missouri WIC logo, those items may continue to be used to depletion and do not need to be discarded. Reasonable attempts shall be made to use these resources prior to the end of FFY 2024.

7.1.020 Contracted Caseload Participation

Authority: 2008 7 CFR 246.16 (d)(2)

Issued: 03/1989

Revised: 10/2009

Policy:

The local agency (LA) shall contract to serve the state agency (SA) projected annual caseload budgeted in the local agency plan (LAP).

The LA shall provide a written request to the SA prior to a planned reduction in service for any purposes deemed necessary by the LA. Such request must be submitted sixty (60) days prior to the implementation and must include a plan for achieving the caseload reduction.

Procedures:

1. The SA projects an annualized caseload of participants to be served for each LA based upon:
   1. Current rate of increase or decrease of LA participants served.
   2. LA's share of statewide caseload based on SA percent of historical LA performance projections, including projected growth or decline based on anticipated funding.
2. The LA shall develop a LAP that describes how the agency will provide efficient, quality service to the allocated caseload.
3. Each month the participant data system counts all of the following participants who receive program benefits.
   1. Women, infants, and children for whom a full or pro-rated food package is issued.
   2. Breastfed infants who did not receive a food package because their mothers requested no supplemental formula.
   3. Partially breastfeeding women, who requests after 6 months postpartum, more than the maximum of formula allowed for a partially breastfed infant will no longer receive a food package but continues to be counted as a WIC participant.
4. The SA reserves the right to reallocate funds based on cumulative caseload of participants served documented in the WIC program data system and projected caseload of participants served. Caseload participation is defined as the number of program participants served during the contract year.
   1. The SA may adjust the annualized contract caseload participation with either an increase or decrease based on a review of participants served at the end of each quarter or more frequently.
      1. Any increase or decrease in caseload participation shall be communicated in writing.
      2. The LA will be allocated an annualized caseload and reimbursed based on actual expenditures during the month, not to exceed the per participant rate for each participant receiving service as stated in the contract.
      3. Reviews of the caseload served and projected may result in contract caseload funding adjustments.
   2. The LA shall provide a written request to the SA prior to a planned reduction in service for any purposes deemed necessary by the LA. Refer to 11.1.040.
      1. Such request must be submitted sixty (60) days prior to the implementation and must include a plan for achieving the caseload reduction.
      2. Upon written approval by the SA, the LA is responsible for notifying current WIC participants and other affected LAs of the proposed caseload reduction and completing the work to transfer participants.

7.1.030 No Shows: Follow Up

Authority: 2008 7 CFR246.6 (b)

Issued: 02/1991

Revised: 01/2011

Policy:

The local agency (LA) shall attempt, at least monthly, to follow up on no-show applicants and participants to reschedule missed appointments.

The LA shall attempt to contact each prenatal applicant who misses her initial appointment to apply for participation in the WIC program within five calendar days of the original appointment in order to reschedule the appointment and shall document such contacts or attempted contacts.

Procedures:

1. The LA shall send appointment reminders with information of the required documentation at the discretion of the Agency.
2. Failure to Keep Appointment
   1. Responsibility for follow up lies with the LA staff at each agency. Follow up with phone calls/appointment notices will be conducted for all appointments as much as possible. The following steps will be taken for those failing to keep appointments for food instrument pick-up, certification or recertification.
      1. LA shall attempt to contact all prenatals who miss their appointment within five days to reschedule their appointment at the earliest possible date.
      2. LA will contact as many other participants as possible to reschedule their missed appointment. Missed appointment notices (letters or postcards) will be mailed to those who cannot be reached or do not have phones.
      3. Follow up activity will be documented in MOWINS in either the Appointment Follow-up screen after the appointment is missed or in the general notes of the participant folder to prove timeframes were met and follow-up was attempted. Refer to 8.1.110 for timeframes.
      4. When using the MOWINS scheduler, a list of missed appointments can be printed from the Missed Appointment Follow Up selection under the activities menu in the participant list. Categories can be selected to assure timeframes are met.
3. End of Month Follow Up
   1. By the end of each month, the follow up report should be reviewed by the LA to identify further action needed. Appropriate contact will be made to those remaining clients who have failed to keep their appointments.
      1. Participants who do not pick up food instruments for two consecutive months or have failed to recertify for 31 days past their certification due date who are not in a new certification will be changed to inactive status from the active MOWINS files.
      2. If the participant returns for an appointment and is still within certification timeframe, the inactive status will be updated on the computer to reflect “reinstated” status and food instruments will be issued.

7.1.040 Waiting Lists

Authority: 2008 7 CFR 246.7(f) (1) & FNS Instr. 803-6

Issued: 03/1981

Revised: 10/2009

Policy:

The local agency (LA) shall establish waiting lists only when/if the contracted year-to-date caseload percentage equivalent is exceeded and when no contract amendment to increase the caseload allocation can be authorized by the SA.

The LA shall establish and maintain waiting lists in accordance with the priority ranking system.

The LA shall explain to applicants why placement on a waiting list is necessary and shall explain the realistic possibilities of receiving future benefits. This must be done within 20 days of the applicant's visit to the LA to request program benefits. LA may not refuse to place any applicant on a waiting list if the applicant requests to be placed on such a list.

For participants due for recertification, the LA shall reassess and determine eligibility status for current priority or sub-priority being served. The LA shall not place on a waiting list any transfer requests whether they come from another state with a valid verification of certification (VOC) or from another LA in Missouri.

When caseload opening occurs at the LA, the agency shall contact applicants on the waiting list to schedule certification appointments or food instrument issuance/nutrition education appointments.

Procedures:

1. Waiting lists are not needed for any priority or sub-priority closed statewide unless placement on one is requested by a participant or applicant.
2. Prior to requesting to establish a waiting list, the LA must:
   1. Track the contracted year-to-date caseload percentage equivalent on the Participant Totals Report.
   2. Determine the projected caseload for the remainder of the fiscal year.
   3. Consult with the state technical assistance (TA) team regarding available funds to reallocate caseload to the LA.
   4. Determine which priorities and/or sub-priorities the LA can continue to serve, based on factors including, but not limited to:
      1. Current caseload characteristics such as:
         1. Percentage in each priority and sub-priority.
         2. Percentage of women, infants and children served.
         3. Size of age groups served for children.
      2. Agency no-show rates.
      3. New and recertification appointments scheduled for the next thirty to ninety days.
3. If funds for reallocation are not available, the state TA team will provide the LA written approval to establish a waiting list. Such approval will include which priorities and subpriorities will go on the waiting list.
4. When approved to establish a waiting list, the LA shall:
   1. Screen the applicant for residency and income eligibility.
   2. Screen the applicant for anthropometric, biochemical, and physical/medical problems.
      1. If medical data (height, weight, and hemoglobin/hematocrit values) are available, the presence of an anthropometric, biochemical, or physical/medical risk can be assessed, which would place the applicant in a higher priority category than if only a dietary inadequacy were present.
      2. If the applicant applies for program benefits without the medical information necessary to determine an anthropometric, biochemical, or physical/medical risk, s/he will be placed on the appropriate lower priority waiting list for those persons having dietary risks only. Self-reported information on past or current medical problems may be accepted by the LA for purposes of assessing the applicant's potential priority.
      3. A dietary assessment may be performed, but is not required to determine the individual's potential priority.
   3. Place the applicant on a waiting list according to his/her potential priority in chronological order of application. For priority assignment, refer to the WIC priority ranking system in the federal regulations CFR 246.7(e) (4).
   4. Inform the applicant, either verbally or in writing, that s/he has been placed on a waiting list. This must be done within 20 days of the applicant's visit to the LA to request program benefits.
   5. For participants due for recertification, the LA shall reassess and determine eligibility status for current priority or sub-priority being served.
      1. If determined eligible for a priority or sub-priority being served, will continue to be served.
      2. If determined eligible for a priority or sub-priority not being served, will be placed next in line on waiting list.
   6. The LA shall not place on a waiting list any transfer requests with a valid VOC. Whether they come from another state or another LA in Missouri, the LA shall serve these persons regardless of priority or sub-priority.
5. The following waiting lists may be established if authorized in the following order:
   1. Priority seven recertified participants. A health assessment is required to determine placement in this priority. Sub-prioritization shall be done in the following order (lowest to highest), as needed:
      1. Non-breastfeeding postpartum women with nutritional status regression.
      2. Children with nutritional status regression.
      3. Breastfeeding women with nutritional status regression.
      4. Homeless or migrant status.
   2. Priority six applicants and participants potentially eligible in this priority.
   3. Priority five certified or recertified applicants and participants. (A health assessment is required to determine placement in this priority). Sub-prioritization shall be done in the following order (lowest to highest), as needed:
      1. Children who have reached their fourth, but not their fifth birthday.
      2. Children who have reached their third, but not their fourth birthday.
      3. Children who have reached their second, but not their third birthday.
      4. Children who have reached their first, but not their second birthday.
   4. Priority four (4) applicants and certified or recertified applicants and participants. (A health assessment is required to determine placement of all except prenatal certified with risk factor 503 (presumptive eligible) in this priority.) Subprioritization shall be done in the following order (lowest to highest), as needed.
      1. Breastfeeding women.
      2. Infants.
      3. Prenatal.
   5. Priority three applicants and participants. Sub-prioritization shall be done in the following order (lowest to highest), as needed.
      1. Children who have reached their fourth, but not their fifth birthday.
      2. Children who have reached their third, but not their fourth birthday.
      3. Children who have reached their second, but not their third birthday.
      4. Children who have reach their first, but not their second birthday.
6. The waiting list shall include, at a minimum, the following information:
   1. Name of applicant or participant.
   2. Name of guardian for infant or child.
   3. Mailing address.
   4. Phone number, message phone, or other method by which agency can contact applicant.
   5. Date(s) applied and/or placed on the waiting list.
   6. Category (i.e. woman & condition, infant, child).
   7. Date of birth.
   8. Expected date of confinement (EDC) for prenatal.
   9. Delivery date for postpartum.
   10. Potential priority.
7. When caseload opening occurs at the LA, the agency shall contact applicants on the waiting list to schedule certification appointments or food instrument issuance/nutrition education appointments if prior health assessment already established eligibility.
   1. Contact applicants by telephone or letter, starting with those individuals on the highest priority waiting list.
      1. Telephone call must:
         1. Be received directly by the adult applicant, the participant or guardian of an infant or child.
         2. Schedule an appointment.
         3. Inform of removal from the waiting list if the appointment is not kept.
         4. If a message must be left for the responsible party, the LA shall follow-up with a second telephone call or with written notification.
      2. Written notification must:
         1. Include the LA return address and telephone number.
         2. Inform of the opportunity to schedule an appointment.
         3. Request a response either in writing or by phone within two (2) weeks of the date the notification is postmarked.
         4. Inform of removal from the waiting list if no response is received.
   2. After all applicants on the highest priority waiting list have been contacted, proceed to other lists in order of priority.
      
      Example: A LA which has been maintaining waiting lists for priorities six and seven now has 25 spaces available for enrollment. The LA would begin contacting applicants from the priority seven waiting list. After all priority seven applicants had been contacted for a certification appointment, the LA would proceed to priority six (6) waiting list.
   3. If a LA does not have sufficient caseload available to enroll all applicants within a priority, the LA may enroll applicants on a first-come, first served basis or on the basis of the severity of the risk factors, as determined by the LA nutritionist/CPA.
   4. If an applicant fails to keep the scheduled certification appointment, s/he shall be removed from the waiting list.
8. A current participant whose priority is lower than applicants on the waiting list shall be disqualified at the end of the current certification period in order to make space available for higher priority applicants. The participant shall then be placed on the appropriate waiting list for his/her priority ranking if the agency reasonably expects to serve that priority in the future.

7.1.050 Clinic Access

Effective: 10/2025

Issued date: 10/2003

Authority references: 2025 7 CFR 246.4(a)(22) and (23); 246.7(b)(2) and (b)(4); 246.7(f)(2)(iii)(A); WIC policy memo 92-1A; ARPA Physical Presence Waiver 2023

Policy:

The local agency (LA) must ensure that employed applicants, participants, authorized representatives, alternate representatives and proxies have access to clinics that require minimal time expenditures.

The LA must ensure that applicants, participants, authorized representatives, alternate representatives and proxies who live in areas with little or no public transportation have access to clinics that require minimal travel distance.

The LA must implement one or more of the practices detailed in the procedures below to minimize time and distance.

The LA must evaluate and address clinic access annually.

Procedures:

1. Providing clinic access.
   1. When scheduling appointments, the LA must inform all applicants, participants, authorized representatives, alternate representatives and proxies of appointments that:
      1. Minimize loss of employment time.
      2. Minimize travel distance and transportation barriers.
      3. Meet processing time frames. Refer to policy 8.1.110.
2. Providing additional clinic access options.
   1. The LA must have in place one or more of the following practices to minimize time and distance:
      1. Schedule and serve individuals by appointment, even if the LA normally does not give appointments.
         1. This does not prohibit serving those without appointments (i.e., walk-ins), but places scheduled appointments ahead of walk-ins.
      2. Allow individuals to be served at the LA of their choosing.
      3. Allow participants who are not high risk to receive food benefits on a bi-monthly or tri-monthly basis.
      4. Allow the authorized representative to send an alternate representative for certification of an infant or child. Refer to policy 8.1.190.
      5. Provide clinic opportunities outside of normal business hours, such as:
         1. Before 8 a.m.
         2. Between noon and 1 p.m. (i.e., coverage over lunchtime).
         3. After 5 p.m.
         4. On a Saturday once or twice a month.
      6. Have clinics no more than 30 miles from any part of the service area.
      7. Have clinics near or on public transportation lines, if applicable or available.
      8. Provide WIC services at specific locations that may include, but are not limited to, major employers, daycare centers or schools.
      9. Implement mobile units that allow clinic access at various locations.
      10. Offer remote certification appointments and services.
      11. Refer to policy 8.1.280.
      12. Other options as approved by the state agency (SA) technical assistance (TA) staff.
3. Maintaining clinic accessibility.
   1. The LA must maintain routine clinic hours to ensure applicants, participants, authorized representatives, alternate representatives and proxies are aware of when they can receive WIC clinic services.
      1. The LA must notify the SA of unexpected changes to the clinic hours (e.g., clinic closings due to inclement weather, structural building issues, WIC staff training or lack of WIC staff).
      2. The LA must notify the SA administrative TA staff of all other clinic changes. This may include but is not limited to, street name changes without a change in physical location or increases to clinic days or hours.
         1. The LA must complete the appropriate Civil Rights Impact Analysis Form. Refer to policy 11.1.040.
      3. The clinic hours must be the same every month unless the SA is notified of unexpected changes, or the appropriate Civil Rights Impact Analysis Form is approved.
4. Evaluating clinic access.
   1. The LA may use the following methods to evaluate clinic access:
      1. Survey applicants, participants, authorized representatives, alternate representatives or proxies to reevaluate clinic access and more effectively meet their needs.
      2. Survey public sites, population sites and public transportation to see what services are available to reduce barriers to WIC services.
      3. Survey city/county census data and/or the public to identify areas of need that should be considered for clinic access in the future.

8.1.010 Participant Confidentiality

Authority: 2023 7 CFR 246.21(b), 246.25(a)(4), and 246.26(d), 45 CFR 164.103 and 164.105, WIC policy memo 2002-2; 2021 RSMo 210.115; 2020 RSMo 210.116; ARPA Physical Presence Waiver 2023; WIC policy memo 2023-6

Issued: 05/1991

Revised: 06/2023

Effective: 10/2023

Policy:

The local agency (LA) shall keep all information obtained from program participants, applicants or other source, or generated as a result of WIC application, certification or participation, which individually identifies an applicant, participant or family member(s) as confidential. The LA shall not disclose individual information to anyone except as provided in this policy.

When confidential information is stored on data systems not supplied by the state agency (SA), the LA shall assure the security is equal to or exceeds that provided by the SA.

Mandated reporting of suspected child abuse or neglect is required by law. The LA shall consult with their legal counsel regarding compliance with the Health Insurance Portability and Accountability Act of 1996 (HIPAA, Title II) and the appropriateness of establishing a hybrid entity status for the WIC services within the agency. The LA shall prohibit the use of cameras, digital or film, within common areas of the facility routinely used by WIC participants.

Procedures:

1. Protecting confidential information
   1. The LA may only release confidential information to persons directly connected with the WIC program. This includes service providers, management and administrators from the LA or SA.
   2. An authorized representative may receive copies of participant information for themselves or the participant for whom they are caring. Refer to policy 8.1.190.
   3. When presented with appropriate documentation and identification, the LA shall provide all the information necessary for audit and compliance investigations to the appropriate authorities as required by WIC regulations and policies. Examples of appropriate authorities include but are not limited to, representatives of the United States Department of Agriculture (USDA), the U.S. Office of the Inspector General (OIG) or the U.S. General Accounting Office (GAO).
   4. The LA shall provide an environment for certification and nutrition education counseling that maintains the confidentiality of applicant and participant information.
   5. The LA shall take reasonable precautions against the theft of data equipment or spying of records containing confidential information.
   6. The LA shall adhere to the following guidelines when obtaining personal health information (e.g., health referral data) and program eligibility (i.e., proof of identity, residency and income) documentation:
      1. The LA must obtain verbal or written consent to obtain personal health information from an agency outside of WIC.
         1. Consent must be documented in MOWINS.
      2. Secured methods must be used to send, receive or view electronic applicant, participant, authorized representative or alternative representative information including proof documentation or personal health information.
         1. Electronic methods that must be secured include but are not limited to, web-based or online video platforms, web-based applications or phone and handheld device applications.
         2. Information that is sent, received or stored must be encrypted or secured in a manner to prevent security breaches.
      3. Personal staff devices or email shall not be used to send, receive or view personal health information or proof documentation.
2. Providing information
   1. Upon receipt of a request for information regarding individual WIC records from any source not listed above, the LA shall:
      1. Require the requester to obtain a signed release specifying the exact information from the adult participant or the parent or guardian of the infant or child participant.
      2. Require the requester to provide photo identification to release information.
      3. Provide copies of the specific materials requested in a secure manner such that only the requester can access the information.
      4. Scan the signed release of information in the participant's folder in MOWINS.
3. Complying with a subpoena
   1. If the LA is issued a subpoena for a participant record, the LA shall immediately notify the SA WIC director or designee and complete the following:
      1. The LA consults with their legal counsel.
      2. With legal counsel, the LA determines if the material requested by the subpoena can be released.
      3. If the LA and their legal counsel decide not to release the information, the LA legal counsel will appear before the court to argue against the release of information requested by the subpoena.
      4. If the court denies the motion to stop the subpoena and requires the LA to release the requested information, the legal counsel should:
         1. Attempt to consider the appropriateness of an appeal of the decision. 
         2. Ensure information produced is only that of which is essential to respond to the subpoena.
         3. Attempt to negotiate the extent to which the WIC information actually produced becomes public information (e.g., reviewed in camera by the court, limited entry into the public record).
      5. If the LA releases the information requested by the subpoena, legal counsel, acting on behalf of the LA, should request the parties requesting the information submit in writing the terms of the release of the subpoenaed information so that all parties are in accord as to the use of the information.
4. Complying with child abuse reporting laws
   1. Child abuse reporting is mandated by Missouri State Law, RSMo 210.115 and 210.116. The LA is required to report suspected child abuse or neglect, even if the information was obtained as part of WIC services.
   2. The LA must comply with the appropriate authorities including the Department of Social Services (DSS) or Children’s Division if there is an investigation regarding suspected child abuse or neglect.
      1. The LA shall release WIC information from a participant file under the following circumstances:
         1. The request for information originates from DSS or Children’s Division.
         2. The request is provided in a formal document from DSS or Children’s Division with the specified information requested clearly stated on the form. The document must include the type of information, timeframe of the requested information and the name of the department or division representative requesting the information. Certain forms may contain a parent or guardian signature but a parent or guardian signature is not required.
         3. The LA shall only provide the specified information requested on the form.
         4. The LA shall scan the formal document requesting information into the corresponding participant folder in MOWINS. Include a general note of the specific information provided, including corresponding timeframes, to whom the information was provided, including contact information and the date the information was sent.
      2. Contact the SA for further guidance when necessary.
5. Complying with a search warrant
   1. The LA shall immediately notify the SA WIC director or designee when a search warrant is presented and complete the following: 
      1. Assure the individual(s) producing the search warrant is (are) apprised of the confidential nature of WIC information.
      2. Review the search warrant carefully and provide only the specific information requested in the search warrant and no other information.
      3. LA and SA legal counsel should be notified immediately after the information has been given for the search warrant.
      4. Scan a copy of the search warrant in the participant folder in MOWINS.
6. Restricting photography
   1. Only SA or LA staff, or contracted photographers, may take photographs for agency use. Contracted photographers must sign a confidentiality agreement form prior to starting work and agree to restrict all images to only WIC use.
      1. Photographic releases must be signed by all individuals whose image is to be used. The LA should consult with its legal counsel for appropriate release forms.
      2. Computer screens and paper records must not be exposed in a way that allows photographic images to be taken of them.
   2. Family or friends may take pictures of members of their own household if given permission by the LA. LA staff must assure that the images are taken in a private area, or in such a way as to protect the privacy of others.
   3. The LA shall assure appropriate signage is posted limiting the use of cameras and all photographic images.
7. Sharing participant data with Department of Health and Senior Services (DHSS) programs
   1. The chief state health officer has authorized WIC to share participant data with DHSS’ Bureau of Immunization Assessment and Assurance (BIAA) for non-WIC purposes for the following reasons:
      1. Establishing the eligibility of WIC applicants or participants for the programs that the organization administers.
      2. To conduct outreach for programs administered by DHSS.
      3. To enhance the health, education and or well-being of WIC applicants and participants currently enrolled in those programs.
      4. To streamline administrative procedures in order to minimize burdens on participants and staff.
      5. To assess and evaluate the state’s health system in terms of responsiveness to participants’ health needs and health care outcomes.

8.1.020 Participant Referrals

Effective: 10/2024

Issued: 01/1981

Authority references: 2024 7 CFR 246.6(b)(5); 246.7(a); 246.7(b)(1); 246.7(b)(3); WIC policy memo 95-10; WIC policy memo 2001-1; WIC policy memo 2001-7; WIC policy memo 2023-5; RSMo 42.051; ARPA Physical Presence Waiver 2023

Policy:

At each certification and mid-certification assessment (MCA), the local agency (LA) shall provide to all participants, authorized representatives or alternate representatives, information on other health-related and public assistance programs and, when appropriate, shall refer participants, authorized representatives and alternate representatives to such programs. The LA should follow up on all referrals made during the last certification period.

At each certification and MCA, the LA shall review a documented immunization record to determine the status of each infant and child and refer to the Bureau of Immunizations as needed.

The LA shall have staff with access to Missouri’s immunization information database, ShowMeVax, available to conduct reviews during clinic operating hours. ShowMeVax access can be obtained using the ShowMeVax instructions.

At each child certification, the participant, authorized representative or alternate representative must be asked if the child has had a blood lead screening or lead test, as determined appropriate for their age and risk factors. If the child has not had a screening or test, a referral must be made to a program(s) where a lead screening or test can be performed. LA staff should provide referrals to women who report being diagnosed with lead poisoning if needed.

The LA shall have a plan for continued efforts to make health services available to the participant, authorized representative or alternate representative at the clinic or through written agreements with health care providers and health care organizations in their service area.

At each certification and MCA, the LA must ask all participants, authorized representatives or alternate representatives about their military service and, if needed, refer them to appropriate military resources.

Procedures:

1. Providing referral resources
   1. The LA shall make a current list of state and local resources available to participants, authorized representatives and alternate representatives and update it annually. The following resources must be included:
      1. Missouri’s Medicaid program, MO HealthNet.
         1. The LA shall refer all WIC program applicants or participants to MO HealthNet who are not currently participating but appear to be below the maximum income limits provided by the state agency (SA).
      2. Drug and substance abuse treatment programs.
         1. Resources are available through the Missouri Department of Health and Senior Services (DHSS) warehouse.
      3. Other DHSS programs and/or community resources.
         1. Medical services.
         2. Dental health services.
         3. Special health care needs services.
         4. Newborn screening program.
         5. Homeless and abuse shelter(s).
      4. Other health services offered at the LA.
         1. Immunizations.
         2. Lead screening.
         3. Family planning.
      5. Military-related services.
   2. Other resources that should be included:
      1. Supplemental Nutrition Assistance Program (SNAP).
      2. Temporary Assistance for Needy Families (TANF).
      3. Local food pantries.
   3. Referral information may be provided to participants through secured electronic means, in person or by mail.
2. Immunization screening
   1. LAs shall, at a minimum, assess all WIC-eligible infants and children for immunization status at certification and MCA visits by reviewing the documented immunization record. The immunization schedule can be found on the DHSS’s immunization website.
   2. The LA shall not refuse WIC services to any infant or child who does not have an immunization record.
   3. Screening of immunization records shall be done by the health professional or the clerical staff.
   4. An immunization screening shall consist of the following:
      1. Reviewing an infant's or child's immunization record from the health care provider or reviewing the record in the ShowMeVax immunization database.
         1. The authorized representative or alternate representative may provide immunization records through electronic means (e.g., a patient portal).
         2. Discharge paperwork or medical records may be used for immunization screening in certain circumstances (e.g., a newborn infant who was recently discharged from the hospital).
      2. If the infant or child is under-immunized or a documented immunization record is not provided by the authorized representative or alternate representative:
         1. Provide information on the recommended immunization schedule appropriate to the current age of the infant or child.
         2. Provide a referral for immunization services, ideally to the child’s usual source of medical care or on-site if available. If the referral is not to the usual source of medical care, it should be specific and should include the address, phone number and hours of operation of the health care provider.
         3. Encourage the authorized representative or alternate representative to bring the immunization record to the next certification visit.
   5. The LA must document the immunization status in the Management Information System (MIS) as “up-to-date” or “not up-to-date.”
      1. If a signed Medical Immunization Exemption form or Parent/Guardian Immunization Exemption form is presented, document it as “not up-to-date.”
         1. The LA is encouraged to document when the authorized representative or alternate representative opts out of immunizations.
      2. If no paper or ShowMeVax immunization record is available, document it as “not up-to-date.”
   6. Appropriate information regarding specific childhood preventable diseases, the benefits of immunization and the Centers for Disease Control and Prevention’s (CDC) recommended schedules for vaccinations for infants and children shall be provided to each authorized representative or alternate representative of an infant or child participant by WIC and/or the immunization staff, according to the established policy at the LA.
   7. WIC allowable cost for immunization screening and referral services:
      1. Personnel costs for screening and referrals may be charged to WIC. This can include personnel time for making appointments.
         1. Personnel costs for providing the immunization shall not be charged to WIC.
      2. Immunization supply costs shall not be charged to WIC.
   8. The LA shall provide all new staff with immunization training within 60 days of the hire or rehire date. The LA must also train all staff annually using the SA-provided training materials. Refer to policy 2.4.010 for LA training documentation requirements.
3. Lead screening
   1. At each child certification, the authorized representative or alternate representative must be asked if the child has had a lead screening or a blood lead test. Refer to the Biochemical Section of the HNAH for WIC’s lead assessment requirements.
      1. Children who have not had a blood lead screening or test must be referred to a testing program. Refer to DHSS’s Blood Lead Testing in Missouri webpage for Missouri’s lead testing requirements.
      2. WIC allowable cost for lead screening and referral services:
         1. Allowable personnel time includes staff time to provide information about lead poisoning prevention to WIC participants, develop an appropriate care plan for children identified as having elevated blood lead levels, provide nutrition education and counseling and make health care referrals.
         2. If blood is drawn and tested for WIC eligibility and lead screening at the same time, WIC and the lead screening program must each pay its fair share of the total cost.
         3. WIC's share of the total cost will not exceed the amount it would pay if it conducted the hematological test for anemia for WIC eligibility separately.
4. Partnering with organizations
   1. The LA’s plan or written agreement to make health services available at the clinic or with local health care providers/organizations shall be attached to the Local Agency Plan (LAP). Refer to policy 4.1.050.
      1. The SA must approve agreements and memorandums of understanding (MOUs).
5. Military service screening
   1. At each certification and MCA, all participants, authorized representatives and alternate representatives must be asked about their military service.
   2. The following question shall be asked:
      1. Have you or an immediate family member ever served in the U.S. Armed Forces?
   3. If yes, the following question must be asked:
      1. Would you like information about military-related services in Missouri?
      2. If yes, the LA must provide a referral using one of the following resources:
         1. The Missouri Benefits and Resource Portal: http://www.veteranbenefits.mo.gov.
         2. The WIC webpage.
6. Documenting referrals
   1. Document all referrals in the MIS.

8.1.030 Conflict of Interest and Separation of Duties

Effective: 03/2025

Issued: 12/1996

Authority references: 2024 7 CFR 246.4(a)(27); WIC policy memo 2016-5; ARPA Physical Presence Waiver 2023

Policy:

The local agency (LA) shall ensure that conflict of interest is avoided and that LA staff are not completing certifications for themselves, relatives or close friends.

The LA shall ensure a separation of duties for the LA staff to safeguard against fraud when determining applicant or participant income and nutritional risk.

Conflict of interest and separation of duties must be maintained for all certifications regardless of service delivery method.

Procedures:

1. Conflict of interest
   1. Conflict of interest can occur when an LA staff member completes a certification that includes determining program eligibility (i.e., identify, residency, income, nutrition assessment/risk factor assignment and food instrument and benefit issuance) for themselves, relatives or close friends.
   2. To avoid a conflict of interest, the LA shall not permit LA staff to complete any part of the certification for themselves, relatives or close friends.
   3. If the LA cannot ensure conflict of interest is avoided, the LA must obtain state agency (SA) approval prior to LA staff conducting any part of the certification for themselves, relatives or close friends.
2. Separation of duties
   1. Separation of duties means one staff member completes the eligibility screening and determination for income, and another staff member completes the nutrition assessment and assigns nutritional risk factors.
      1. Either staff member may issue food benefits to that same participant.
   2. To ensure separation of duties is maintained, LAs shall have a minimum of two LA staff members available to perform certification functions and duties (e.g., income eligibility screening and determination and nutritional risk assessment and assignment).
   3. LAs who allow one staff member to perform all eligibility and certification functions (i.e., income eligibility determination, nutrition assessment/risk factor assignment and benefit issuance) must complete the following:
      1. Within two weeks, the LA must complete a review of each clinic day separation of duties was not maintained. i. A WIC coordinator, nutrition coordinator or other LA staff member approved by the SA must complete the review(s).
         1. A WIC coordinator, nutrition coordinator or other LA staff member approved by the SA must complete the review(s).
         2. The LA must use the Separation of Duties report to conduct the review(s). Refer to the Guide to Separation of Duties Report.
         3. The review(s) must contain all non-breastfeeding infant certification records and at least 20% of a random sample of the remaining certification records completed on those days.
         4. The person(s) who completed the certification shall not complete any portion of the review.
      2. If the LA does not have a WIC coordinator, nutrition coordinator or other LA staff member approved by the SA who is able to complete the review, contact WICMonitoring@health.mo.gov within three days of the occurrence.
      3. The review(s) must be kept on file and made available for the SA to review during monitoring.
3. Fraud or abuse
   1. The LA must notify WICMonitoring@health.mo.gov immediately if it appears fraud or abuse may have occurred.

8.1.040 Value of WIC Benefits

Authority: CFR 246.26(a)

Issued: 04/2000

Revised:

Policy:

WIC benefits are not considered income.

Procedures:

1. The federal regulations clearly state that WIC benefits are not to be considered as income or resources of participants.
2. When a participant asks the local agency (LA) to provide a statement of the value of their WIC benefits, the agency should do the following:
   1. Inform the participant of the federal regulation that exempts their WIC benefits from income.
   2. Copy section 246.26(a) of the WIC Program Consolidated Regulations to provide to the requester.
3. For questions or concerns regarding this regulation or issue, contact the state agency.

8.1.050 Proof of Pregnancy

Authority: 2023 7 CFR 246.4(a)(11)(i)(C); 246.7(c)(2)(ii); 246.7(c)(4); ARPA Physical Presence Waiver 2023; WIC policy memo 2023-6

Issued: 04/2008

Revised: 03/2023

Effective: 10/2023

Policy:

The local agency (LA) shall ensure all WIC applicants and participants are eligible for the Missouri WIC program. The LA may issue benefits to applicants who claim to be pregnant (assuming that all other eligibility criteria are met) but whose pregnant condition is not visibly noticeable and does not have documented proof of pregnancy at the time of the certification interview. The LA may opt to request proof of pregnancy at any time during the certification period. Proof of pregnancy, when requested, shall be from a health care provider, public health department, pregnancy resource center or other reliable medical or social service when there is reasonable doubt the pregnancy exists. Proof of pregnancy shall not be an expense to the applicant or participant.

Procedures:

1. Assessing prenatal eligibility
   1. Complete the certification requirements as determined by federal guidelines and the Missouri WIC program. Refer to policy 8.1.070.
   2. If the LA has reasonable doubt that the pregnancy exists, provide the participant with two months of benefits by placing them on a bimonthly cycle.
      1. Reasonable doubt considerations:
         1. A WIC applicant or participant has stated that she was pregnant in the past, but there was never a visible sign of pregnancy and no birth occurred.
         2. A third party notifies the LA that the WIC applicant or participant is not pregnant.
      2. The LA may contact the state agency (SA) for guidance if there is reasonable doubt that the pregnancy exists.
2. Obtaining prenatal eligibility data
   1. Electronic documentation for proof of pregnancy may be provided in person or sent to the clinic via secured electronic means. Refer to policy 8.1.010.
   2. If the LA opts to request proof of pregnancy, prenatal documentation may be received prior to the certification appointment.

8.1.060 Physical Presence at Certification or Mid-certification Assessment

Authority: 2016 7 CFR 246.7 (o)(1)(2), MPSF-1: WC-01-07-P

Issued: 10/1989