WIC Operations Manual (WOM)

VIII. Certification Eligibility and Coordination of Services

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:

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.
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.
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.
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.
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.
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.
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:

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.
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.
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.
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).
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.
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:

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.
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.
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:

The federal regulations clearly state that WIC benefits are not to be considered as income or resources of participants.
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.
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:

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.
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

Revised: 02/2017

Policy:

The LA (LA) shall require that the person being certified be physically present at the time eligibility for the WIC Program is determined or the midcertification assessment (MCA) is completed, with limited exceptions allowed.

Procedures:

Physical Presence Requirement:
1. Individuals seeking participation in the WIC program must be physically present when determining eligibility or completing the MCA unless the applicant, participant, parent or guardian meetsthe limited exceptions allowed.
Exceptions for Physical Presence:
1. Reasonable Accommodation of Disabilities.
  1. If an applicant, participant, parent, or guardian has a disability that makes it difficult to come to a clinic for certification, or 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.
  2. Examples of disabilities creating a current barrier are:
    1. A newborn infant with medical complications.
    2. A medical condition that necessitates the use of medical equipment not easily transportable.
    3. A medical condition requiring confinement to bed.
    4. A serious illness that may be exacerbated by coming into the clinic.
    5. A highly contagious illness that may be readily communicated to others by coming into the clinic.
  3. The applicant, participant, parent, or guardian shall provide documentation from a physician or primary care provider stating the disability status and length of disability.
2. Receiving Ongoing Health Care.
  1. An infant or child who was present at his/her initial WIC certification and is receiving ongoing health care may be exempt from the physical presence requirement, if being physically present would pose an unreasonable barrier.
3. Working Parents or Caretakers.
  1. 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.
    1. The child must have one or more working parents/primary caretakers for the exception to apply.
    2. The LA shall obtain a statement from the parent(s)/caretaker(s) documenting his/her employment and work hours.
4. Infants Under Eight (8) Weeks of Age.
  1. Infants under eight (8) weeks of age who cannot be present at certification for a reason determined appropriate by the LA and for whom all necessary information is provided.
  2. Document reason for absence in a General Note or SOAP Note in MOWINS.
The LA must document whether the applicant or participant is physically present.
The participant, guardian or caretaker shall provide the LA with appropriate medical referral data and anthropometric measurements, which have been collected within 60 days prior to date of certification or MCA and must reflect current health status.
Statute of Limitation
1. The exemption from physical presence shall be handled on an individual basis and only applies to the certification period for which applying. At each certification, the request for exemption from physical presence must be reassessed.
2. Any long-term permanent disabilities requiring exemptions for physical presence must be approved by the SA, and the documentation must be maintained in the participant's file.

8.1.070 Certification

Effective: 10/2025

Issued: 01/1981

Authority references: 2025 7 CFR 246.2, 246.7, 246.11(e)(5); MPSF: WC-08-07-P; WIC PM 2011-5; MPSF:WC-92:10; Final WIC Policy Memo 2001-2; Final WIC Policy Memo 2008-4; ARPA Physical Presence Waiver 2023

Policy:

The local agency (LA) certifying staff must assess participants and assign all identified risk factors following guidance and procedures in the United States Department of Agriculture (USDA) regulations, USDA nutrition risk criteria and Missouri Risk Factor Reference Guide.

Each applicant must have a WIC nutrition and breastfeeding assessment (i.e., nutrition assessment) to determine eligibility as required by federal guidelines and the Missouri WIC program. Nutritional risk is based on anthropometrics (i.e., height/length and weight), blood work (i.e., hemoglobin), nutrition assessment, screening for immunizations and health history. All information obtained must be documented in the Management Information System (MIS). These assessments and screenings guide how each participant’s general nutrition education, referrals and food package must be tailored to address their individual nutritional needs. Infants, children and breastfeeding women certified for over six months must have a WIC mid-certification assessment (i.e., MCA) to maintain quality nutrition services. An MCA must include anthropometrics, blood work (as needed), an immunization screening and a nutrition assessment to ensure that health and nutrition services are not diminished.

The initial certification is the first time a person is certified as eligible for the WIC program in Missouri. Any certification that occurs after the initial certification, regardless of a change in category, is considered a subsequent certification as long as there has not been a break in service of one year or more. Subsequent certifications take place after the initial certification and represent participants who are reapplying for WIC eligibility.

Initial certifications must be completed in person for all participants. Subsequent certifications and MCAs may be completed remotely if determined to be appropriate by the competent professional authority (CPA) or nutritionist.

Procedures:

Procedures:
Certification and MCA requirements.
The LA staff must practice within their scope of work and according to their job duties as described in policies 2.4.030, 2.4.050 and 2.4.070.
The participant must be assigned nutrition risk factors at certification or MCA based on anthropometrics, blood work and the nutrition assessment. All participants must have at least one risk factor to qualify for the WIC program. Refer to the Risk Factor Reference Guide for detailed information on risk factors. All identified risk factors must be assigned in the MIS.
1. Risk factors may be assigned automatically by the MIS when demographic, anthropometric, blood work and immunization data is entered. Additional risk factors may be manually assigned by the CPA or nutritionist.
2. Self-reported and physician-reported risk factors must be accompanied by the following documentation in the MIS.
  1. The name and contact information of the health care provider.
  2. If prescribed, name of special diet, formula or medication.
  3. Any supporting medical documentation should be maintained in the participant’s file in the MIS.
3. Risk factors identified at any time during the current certification period must be assigned and may change the participant’s priority or make them high-risk.
4. The documented risk condition must apply to a participant’s current or most recent nutrition risk condition versus any history of the condition unless otherwise stated in the specific definition of the nutrition risk criteria.
5. Priority is automatically assigned by the MIS based on category and risk criteria.
The LA must acquire and maintain accurate health assessment equipment (scales and measurement boards). Refer to the Health and Nutrition Assessment Handbook for minimum criteria and maintenance guidelines for weighing, measuring and blood work equipment.
The LA must attempt to collect anthropometrics (i.e., height and weight) and, if appropriate, blood work (i.e., hemoglobin) at certification and MCA. See section F for the ideal timeframes for collecting blood work.
1. Height, weight and hemoglobin should be collected while the participant is in person at the clinic if the measurements were not provided before the certification or MCA appointment through health referral data.
  1. Health referral data must be provided in person or via secured electronic means. If the authorized representative granted permission, the LA may contact the participant’s health care provider or local public health agency (LPHA) to obtain data. Refer to 8.1.010.
    1. Anthropometric data provided to the LA must not be older than 60 days and must reflect current health and categorical status. Measurements received through referral data should be documented in the MIS as Outside of Clinic.
    2. Blood work data provided to the LA must not be older than 90 days and must reflect current health and categorical status.
    3. Records from the participant’s health care provider or LPHA must be reviewed by LA staff and destroyed once the data has been documented in the MIS.
    4. The LA must not accept self-reported data except when determining a prenatal woman’s pre-pregnancy weight.
  2. If the LA cannot collect accurate anthropometrics or blood work at either certification or MCA, the LA must attempt to collect missing data at the next appointment.
    1. The participant must be placed on a monthly benefit cycle until missing data is provided to the LA or collected in person at the clinic.
    2. The LA staff must document each attempt to collect missing data in the MIS.
      1. LA staff must document each attempt to collect anthropometric data as an alert and copy it into a general note.
      2. The Delayed Blood Work box must be used to document missing blood work data. The MIS will add an alert and require a general note.
      3. The alert and general note must indicate missing data and why the attempt was unsuccessful.
    3. If additional risk factors were assigned once the missing data has been obtained, the CPA or nutritionist must schedule a follow-up appointment to reassess and tailor nutrition services.
LA staff must attempt to collect blood work at the clinic or through referral data at the ideal time frames listed below:
1. All infants should have blood work collected on or after 9 months of age and prior to their first birthday.
2. All children should have blood work collected once between 12 through 24 months of age. It is recommended to be done at 15 through 18 months of age, ideally six months after the infant blood work.
  1. f the blood work is below recommended levels as an infant, it is suggested that blood work be collected again at 15 months of age.
3. All children 2-5 years of age should have blood work collected once every 12 months.
  1. Blood work data for 2 years of age may be collected as early as 22 months of age.
  2. Blood work must be rechecked at the next certification or MCA visit if risk factor 201 was assigned.
4. All postpartum women should have blood work collected, regardless of pregnancy outcome, ideally between four and six weeks postpartum. Blood work must not be collected before four weeks postpartum. If they are certified after six weeks postpartum, blood work must be collected at the time of certification.
  1. No additional blood work is necessary for breastfeeding women at MCA.
5. All prenatal women should have blood work collected at certification.
6. The following are exempt from blood work:
  1. An applicant whose religious beliefs prohibit blood draws.
  2. An applicant with a documented medical condition (e.g., hemophilia, fragile bones/osteogenesis imperfecta, a serious skin condition, leukemia or thalassemia) in which the procedure could cause harm to the applicant. Physician documentation of the condition is required.
  3. The appropriate exemption must be documented in the HT/WT/Blood tab in the MIS.
A nutrition assessment must be completed by a CPA or nutritionist on the day of certification and MCA and documented in a Subjective, Objective, Assessment and Plan (SOAP) note. (Refer to the Nutrition Assessment section of the HNAH).
1. The nutritionist must assess high-risk participants and provide all high-risk general nutrition education and follow-up. For follow-up contact documentation requirements, refer to policy 2.4.110.
  1. A nutritionist must document it in a SOAP note.
  2. A CPA must document in a SOAP note, place the participant on a monthly benefit issuance cycle and schedule the participant’s follow-up appointment with the nutritionist.
2. A CPA or nutritionist may change a woman’s category from breastfeeding to nonbreastfeeding only after appropriate counseling is provided. The woman must have had at least one risk factor other than 601 or 602 assigned during her breastfeeding certification for the agency to complete a breastfeeding to nonbreastfeeding category change in the MIS. If no other risk factors were assigned, the agency must complete a nonbreastfeeding certification by completing all requirements as indicated in section A.
3. General nutrition education must be tailored based on the nutrition assessment. It must be offered on the day of certification, MCA and subsequent visits. Refer to policy 2.4.110 for the frequency that it must be offered based on certification length.
  1. Substance use information must be provided to all authorized or alternate representatives at each certification and on an as-needed basis at subsequent visits. Refer to policy 2.4.110 for guidelines on documentation.
4. At each certification and MCA, all participants must be provided with a current list of available local resources and information on other health-related and public assistance programs (i.e., Resource List). LA staff must document when they provide the Resource List and specific referrals under the Referrals tab in the MIS.
  1. Throughout certification, specific referrals must be provided and documented when appropriate.
Labor Delivery Recovery Postpartum (LDRP) hospital certifications must comply with all current WIC policies. The CPA or nutritionist must complete the certification in person.
1. Participants must be placed on a monthly cycle.
2. The certifying agency must set an alert and document in a SOAP note. The alert and note must:
  1. performed the certification.
  2. Indicate appropriate follow-up needed.
  3. Refer to section G.1 above for high-risk follow-up requirements. Participants with risk factors 602 or 603 should be referred to the hospital lactation consultant or LA breastfeeding expert for immediate follow-up for breastfeeding complications.

8.1.080 Program Explanation

Effective: 08/2025

Issued: 01/1981

Authority references: 2025 7 CFR 246.7(a) and (j); 246.12(r)(3); WIC policy memo 2008-1; ARPA Physical Presence Waiver 2023; WIC policy memo 2023-6

Policy:

The local agency (LA) must provide an explanation of the WIC program to each applicant, participant, authorized representative or alternate representative at certification appointments.

The program explanation must include general information about the WIC program, nutrition services, the participant’s rights and responsibilities, food benefit redemption and food instrument use.

The initial certification is the first time a person is certified as eligible for the WIC program in Missouri. Any certification that occurs after the initial certification, regardless of whether a change in category occurred, is considered a subsequent certification as long as there has not been a break in service of one year or more. Subsequent certifications take place after the initial certification and represent participants reapplying for WIC eligibility.

The program explanation is separate from nutrition education.

Procedures:

Participant’s rights and responsibilities
1. The LA must provide the participant’s rights and responsibilities using the WIC Participant’s Rights and Responsibilities form (WIC-10) or other approved state agency (SA) tool at all certifications.
  1. The participant’s rights and responsibilities must be provided to applicants, participants, authorized representatives or alternate representatives prior to or on the day of the certification appointment. Refer to policy 8.1.280.
  2. The individual must read or have read to them the participant’s rights and responsibilities to ensure they are informed of their rights and acknowledge their understanding by providing their signature.
  3. If a participant refuses to provide a signature, explain that benefits cannot be provided.

Initial certification requirements.

The initial certification appointment must include the program explanation components listed below. Refer to policies 2.4.050, 2.4.070 and 4.1.020.
Nutrition services. a. The nutrition services information must be explained at initial certifications verbally or through the use of digital, written, printed or other SA-approved tools that include the information below:
1. The purpose of the WIC program is to provide nutritional support (i.e., routine education and strategies for a healthy diet, supplemental foods, referrals and breastfeeding promotion and support) during critical times of growth and development to improve health and achieve positive health outcomes. The nutrition assessment process is necessary to identify nutrition needs (e.g., medical conditions, dietary practices) and interests.
2. The relationship between WIC staff and the participant is a partnership with open dialogue and two-way communication.
3. WIC food benefits are prescribed for the individual to support the participant's nutritional well-being and help them meet the recommended intake of important nutrients and foods.
4. The food provided by WIC is supplemental and is not intended to provide all of the participant's daily food requirements.
5. Participants must reapply at the end of the certification period and be reassessed for program eligibility.
6. If the LA is not serving all priorities, explain the nature of the WIC priority system and the priority designation for the individual. Refer to the Risk Factor Reference Guide and policy 7.1.040.

Food benefit redemption and food instrument use.

The food instrument, food benefit and food redemption information must be explained at initial certifications verbally or through the use of digital, written, printed or other SA-approved tools that include the information in the table below:

How to:	They are responsible for:
Use the food instrument and WICshopper app. Find authorized WIC retailers in the service area where food benefits can be redeemed. Shop for fresh produce and be familiar with the WIC mapping of fresh produce. Read a receipt and request a balance inquiry at the retailer. Contact the customer service line to set the personal identification number (PIN) or obtain a balance inquiry. Obtain a new food instrument if one is lost, stolen or damaged. File a complaint if they feel they have been treated unfairly at an authorized WIC retailer.	Maintaining the safety, security and privacy of the food instrument and PIN. Obtaining food benefits before they expire at 11:59 p.m. on the last day of the month. Understanding that requesting to refund or exchange a WICapproved food item for a non-WIC-approved food item, cash or store credit is a program violation. This includes buying, selling, trading or giving away WIC food benefits. Acknowledging that the participant and/or the authorized representative will be held responsible for any program violations.

How to:

They are responsible for:

Use the food instrument and WICshopper app.
Find authorized WIC retailers in the service area where food benefits can be redeemed.
Shop for fresh produce and be familiar with the WIC mapping of fresh produce.
Read a receipt and request a balance inquiry at the retailer.
Contact the customer service line to set the personal identification number (PIN) or obtain a balance inquiry.
Obtain a new food instrument if one is lost, stolen or damaged.
File a complaint if they feel they have been treated unfairly at an authorized WIC retailer.

Maintaining the safety, security and privacy of the food instrument and PIN.
Obtaining food benefits before they expire at 11:59 p.m. on the last day of the month.
Understanding that requesting to refund or exchange a WICapproved food item for a non-WIC-approved food item, cash or store credit is a program violation. This includes buying, selling, trading or giving away WIC food benefits.
Acknowledging that the participant and/or the authorized representative will be held responsible for any program violations.

If the participant or authorized representative receives the initial program explanation, repeating the above information may not be needed for initial certifications of additional household members (e.g., the initial certification of an infant to a mother who has received the program explanation during her pregnancy).

Subsequent certification requirements.
1. The LA must offer to review information in section B using SA-approved tools at subsequent certifications. The following situations may necessitate a review of section B:
  1. A break in service of one year or more.
  2. When a violation of any program requirement has been committed.
    1. The LA must repeat the sections that are related to the violation.
  3. Applicant or participant request.
2. Household and authorized representative changes.
  1. The LA must follow the procedures in sections A and B above when a household change or a change in the authorized representative occurs at the certification appointment or during the certification period. Refer to policy 8.1.190.
Other WIC appointments.
1. All other WIC appointments must include the following:
  1. The LA must ask the participant, authorized representative or alternate representative if changes need to be made to the participant’s food package.
    1. Refer them to the competent professional authority (CPA) or nutritionist if a change is requested.
  2. The LA must ask the participant, authorized representative or alternate representative if they have any issues or concerns at the retailer. Refer to policy 1.1.010.
Documenting.
1. The LA must document in a general note in the Management Information System (MIS) when the program explanation is provided.

8.1.100 Next Steps for Health (Exit Counseling)

Effective: 04/2024

Issued: 09/1995

Authority references: WIC policy memo 94-43; ARPA Physical Presence Waiver 2023

Policy:

Next Steps for Health counseling shall be offered to all women (prenatal, postpartum and breastfeeding) by the end of their certification to reinforce the importance of nutrition and health messages received through WIC. The program benefits of nutrition education will empower participants to make healthier food choices beyond their current certification.

Procedures:

Next Steps for Health counseling must be provided by the competent professional authority (CPA) or nutritionist in person or remotely. Refer to policy 2.4.110 section B. Counseling shall include, at a minimum, an explanation on all of the following:
1. The importance of folic acid intake for preventing birth defects.
2. The importance of breastfeeding as the preferred method of infant feeding and the continuation of breastfeeding for the infant's health during at least the first year of life.
3. The importance of keeping immunizations current (for themselves and their children).
4. The health risks of alcohol, tobacco and other drug use.
5. The importance of a well-balanced diet.
Offer the Next Steps for Health brochure to reinforce the WIC message or a comparable resource approved by your state nutritionist technical assistant. The CPA or nutritionist may offer an abbreviated counseling session for postpartum or breastfeeding women who were previously provided this information as a prenatal participant.
Next Steps for Health counseling shall be offered at a visit other than the day eligibility is determined. If a pregnant participant only has a certification appointment before delivering her child, Next Steps for Health counseling is not required to be completed during her prenatal certification.
Next Steps for Health counseling should be provided in addition to risk-specific nutrition education when appropriate.
Document the contact in the Missouri WIC Information Network System (MOWINS) as Next Steps for Health (Exit Counseling). If a comparable resource was used in place of the Next Steps for Health brochure, it must be documented in a general or a subjective, objective, assessment and plan (SOAP) note.

8.1.110 Time Frames for Applicant Processing

Effective: 10/2025

Issued: 10/2009

Authority references: 2025 7 CFR 246.7(b)(5) and 246.7(f)(2)

Policy:

The local agency (LA) must process all requests for program benefits, within the time frames required by federal regulations.

The LA must document all appropriate contact information to ensure compliance with the time frames and follow-up.

Procedures:

Processing requests for WIC benefits.
1. The application process begins when a categorically eligible applicant contacts the LA with the intent to make a request for program benefits during regular LA business hours.
  1. Applicants who request program benefits outside of the LA’s normal business hours must be contacted the following business day.
2. If the applicant cannot be assessed for program eligibility and certified on the day initial contact is made, the LA must record demographic information in the Management Information System (MIS) prescreening tool.
  1. The LA must document the initial contact date and should collect income information, if available. Inform the applicant if they do not meet income eligibility requirements and follow the procedures in the Notice of Ineligibility Guide. Refer to policy 8.1.170.
3. If the applicant meets the income eligibility guidelines, the LA must schedule a certification appointment to complete program eligibility requirements according to the following time frames:
  1. Within 10 calendar days from the date of the request for services for:
    1. Prenatals.
    2. Infants under six months old.
    3. Breastfeeding women.
    4. Members of the migrant population who plan to leave the LA’s service area.
  2. Within 20 calendar days from the date of the request for services for:
    1. Infants over six months old.
    2. Children.
    3. Nonbreastfeeding women.
4. LAs who are currently operating clinic days more than 10 days apart must:
  1. Serve participants on a non-clinic day within 10 days of the initial request, or they may request a five-day extension to the 10-day time frame under the following guidelines:
    1. The LA must complete the appropriate Civil Right Impact Analysis Form (WIC-34C) indicating the request to serve participants within 15 days of the initial request. The SA must approve the extension before implementation. Refer to policy 11.1.040.
    2. If approved to operate with the five-day extension, LAs must provide referrals to appropriate resources and refer applicants and participants to other clinics that can schedule an earlier certification appointment date. Document all referrals in the MIS.
5. Inform the applicant, participant, authorized representative or alternate representative of the following:
  1. The certification appointment is for health assessment and program eligibility determination.
  2. They must provide proof of income, identity and residency.
  3. All individuals to be assessed must be present at the initial certification visit unless an exemption applies. Refer to policies 8.1.060 and 8.1.280.
  4. The authorized representative or alternate representative of the infant or child applicant must be present at certification appointments to verify the information and sign for the participant's rights and responsibilities. Refer to policies 8.1.060, 8.1.190 and 8.1.200.
Eligibility processing.
1. Neither the LA nor its contracted designees will charge the applicant, participant, authorized representative or alternate representative for services, tests, forms or brochures used to determine eligibility or provide WIC services.
2. When an LA cannot schedule an appointment within the appropriate time frames as defined in this policy, the LA must contact the state agency (SA) immediately to determine the steps necessary to correct the situation.
3. Individuals due for subsequent certification must not receive priority over new applicant requests. Subsequent certifications must be scheduled appropriately according to their program category.
4. Refer to policy 7.1.040 for waiting list procedures.
Conducting certification appointments.
1. Complete the certification process in the MIS to determine program eligibility. Use backup certification forms when necessary. Refer to policy 3.1.050.
  1. If eligible, the LA must provide program benefits, including nutrition education, breastfeeding promotion and support, food instruments and food benefits on the same day.
  2. If ineligible, the LA must follow procedures in policy 8.1.170. Refer to the Notice of Ineligibility Guide.

8.1.120 Residency Requirements

Authority: 2023 7 CFR 246.7(c)(l)(i); 246.7(c)(2)(i); WIC policy memo 99-4; FNS final rule 77245: Certification Integrity; PL 105-336; ARPA Physical Presence Waiver 2023; WIC policy memo 2023-6

Issued: 05/1991

Revised: 04/2023

Effective: 10/2023

Policy:

The local agency (LA) shall ensure applicants and participants meet the Missouri WIC program residency requirements. The applicant or participant must reside in Missouri, with limited exceptions, to be certified as eligible for the WIC program.

Residency shall be defined as the location or address where an applicant or participant routinely lives or spends the night and need not represent a legal residence.

Procedures:

Assessing residency eligibility
1. The LA must verify Missouri residency through documentation from the applicant or participant.
  1. Proof of residency is not required to be in the name of the applicant or participant but must provide proof of the physical address where the applicant or participant routinely lives or spends the night.
  2. Length of residency is not a requirement to program eligibility and proof of residency should be implemented in a way that does not constitute a barrier to the applicant.
2. The LA shall serve applicants or participants who reside outside of their service area.
  1. Applicants or participants have the option to be served by the LA they choose, regardless of the service area in which they live or work.
3. The LA shall inform the applicant, authorized representative, alternate representative or participant of the need for residency proof for the household when scheduling a certification appointment.
4. The LA shall request proof of residency when a WIC participant is transferring to Missouri from another state. A Verification of Certification (VOC) card or document does not represent proof of residency. Refer to policy 8.1.160.
Obtaining residency eligibility data
1. Electronic documentation for proof of residency may be provided in person or sent to the clinic via secured electronic means. Refer to policy 8.1.010.
2. Proof of residency documentation must be the most recent issued version or current form available. Acceptable proof of residency includes:
  1. Documentation of current participation in an adjunctively eligible program (e.g., SNAP, TANF or MO HealthNet).
    1. The LA must use a state agency (SA) approved adjunct program database to verify current residency (e.g., MOHSAIC).
    2. The applicant or participant must provide their current address. The LA must verify the address provided against the address in the approved adjunct program database.
    3. Additional documentation is needed if the data in the adjunct program database is not current or not accurate.
  2. Current utility bill/personal bills (e.g., credit card bill, student loan statement).
  3. Current rent or mortgage receipt.
  4. Voter registration card.
  5. Property tax receipt.
  6. Employer-issued documents (e.g., pay stub, W-2) that include name, physical address and issued date.
  7. Correspondence from a government office that does not provide WIC services (e.g., jury summons, social services letter).
  8. Written statement from a reliable third party that has knowledge of the applicant's or participant's regular fixed or nighttime location. Reliable parties may include staff of a social service agency, church, legal aid society, shelter or employer.
    1. The LA must document the third-party verifier information in MOWINS under general notes or scan a copy of the third-party statement into the participant’s folder.
  9. Approved hospital record such as hospital chart when completing a hospital certification.
  10. Foster care placement letter.
  11. Signed statement used for exceptions. Refer to part 4 for exceptions.
3. A PO Box does not constitute sufficient documentation of residency.
4. Exceptions
  1. Disaster, homeless or migrant considerations.
    1. The LA may authorize the certification of applicants when no proof of residency exists, such as when an applicant or an applicant's parent or guardian is a victim of theft, loss or disaster; a homeless individual; or a migrant farmworker. In these cases, the LA must require the applicant to confirm their proof of residency in writing.
    2. If the LA becomes aware of a physical address change within a certification period, proof of residency may be requested if an exception (signed statement) was utilized at the certification appointment.
      1. Notate the residency documentation viewed in MOWINS under general notes.
  2. An individual who lives in a shared border state may be served in Missouri if they work or receive health care in Missouri.
    1. The LA must take precautions to prevent dual participation by contacting the WIC program in the state from where the applicant resides.
    2. The LA must document the contact with the other state WIC program in the participant’s folder under general notes in MOWINS.
    3. This exception can be made with justification and approval from the SA.
Documenting residency eligibility
1. The LA shall indicate and select the type of document viewed to provide proof of residency in MOWINS.
2. If a signed statement is used for exceptions, the LA shall select the exception option in MOWINS and scan the signed statement into the participant's folder. Refer to policies 4.1.060 and 2.4.090.

8.1.130 Income Requirements

Authority: 2023 7 CFR 246.4(a)(6); 246.7(d) and (h); WIC policy memo 99-4; WIC policy memo 2003-3; WIC policy memo 2013-3; ARPA Physical Presence Waiver 2023; WIC policy memo 2023-6

Issued: 01/1981

Revised: 02/2023 Effective 10/2023

Policy:

The local agency (LA) shall determine income through the use of a clear and simple application form provided or approved by the state agency (SA).

The LA shall ensure applicants provide documentation of family income at certification, except in limited situations.

In determining the income eligibility of an applicant, the LA shall use the income of the family, household or economic unit during the past 12 months and the family's current rate of income to determine which indicator more accurately reflects the family's status.

Procedures:

Assessing income eligibility
1. The LA shall perform adjunct eligibility verification for each certification. Refer to policy 8.1.260.
2. The LA shall inform the applicant, participant, authorized representative or alternate representative of the need for proof of income documentation for the household when scheduling a certification appointment if adjunct eligibility does not apply.
3. Refer to policy 8.1.160 for verification of certification (VOC) procedures.
4. Custody considerations
  1. If there is a custody dispute, the infant or child is counted in the household of the guardian on record. The person disputing the guardianship must supply documentation to the agency to verify a change in guardianship.
    1. The LA must reassess income if the custody of an infant or child changes during a certification period.
  2. The LA shall place the infant or child on a monthly issuance cycle until the custody dispute is resolved.
  3. Refer to the district administrative technical assistance staff (TA) for additional considerations.
5. Foster children
  1. A foster child is considered to be a household of one and is separate from the rest of the foster family or household. Refer to policy 8.1.260 for adjunct eligibility.
Obtaining income eligibility data
1. Electronic documentation for proof of income may be provided in person or sent to the clinic via secured electronic means. Refer to policy 8.1.010.
  1. Income documentation must not be submitted to the LA more than 30 days prior to the appointment.
2. Income for the purposes of this part means gross cash income before deductions for income taxes, employees' social security taxes, insurance premiums, bonds and others.
  1. The LA shall assess current household size to determine income eligibility. Refer to policy 8.1.140.
3. No deductions from income are allowed, regardless of expenses or hardship.
  1. The LA shall determine if annual or current income is the best indicator of eligibility for each certification.
  2. Current income is the most recent available proof of 28-31 consecutive days’ worth of income received by the household.
    1. The most recent available proof must not be dated more than 30 days prior to the income documentation submission date or certification appointment date, whichever is earlier.
    2. LA staff shall determine the number of documents needed to substantiate current income based on the applicant’s or participant’s circumstances. If pay is consistent, only one pay stub per income source is required.
    3. If income is being assessed prospectively (e.g., the sole support of that family has just been laid off, but has been authorized to receive unemployment benefits for the next six months), current income refers to income that will be available to the family in the next 30 days.
  3. Annual income is income received in the most recent 12 months prior to the date of application. Some examples of when annual income might be appropriate include:
    1. Those who work at irregular times or seasonally.
    2. Those on a temporary leave of absence.
    3. Teachers who are paid on a 10-month basis.
    4. Self-employed individuals.
    5. Families of military and military reservists (e.g., reenlistment bonuses, hazardous duty pay).
  4. Both farm and non-farm self-employed persons are assessed for WIC income eligibility using net income rather than gross income.
4. Examples of acceptable proof of income documentation include:
  1. Current pay stub or a signed statement from the employer indicating gross earnings for a specified period. Pay frequency must be indicated (e.g., weekly, biweekly, monthly).
  2. Commissions, fees and tip records.
  3. W-2 forms or income tax returns for the most recent calendar year.
  4. Unemployment letter or notice.
  5. Check stub or award letter from Social Security stating the current amount of income.
  6. Recent Leave and Earnings Statement (LES) for military personnel.
  7. Recent bank statement.
    1. Use caution when assessing income from a recent bank statement as earnings and wages are typically net income, not gross.
  8. Divorce decree which states alimony and/or child support.
  9. A scholarship letter.
  10. Accounting records for those who are self-employed.
  11. Other sources of income not listed above must be documented in the general notes in the participant folder in MOWINS.
5. The type of document viewed to provide proof of income must be noted electronically in the income screen in MOWINS.
6. The LA may require verification of information it determines necessary to confirm income eligibility for WIC benefits. Verification is a process whereby the information presented, such as pay stubs, is validated through an external source of information other than the applicant. Such external sources include employer verification of wages, local welfare office verification and others.
7. Income inclusions:
  1. Monetary compensation for services, including wages or salary, commissions, fees, tips and training stipends.
  2. Net income (i.e., gross receipts less operating expenses) from farming self-employment, non-farming self-employment, rental property and royalties.
  3. Social Security benefits.
  4. Public assistance, private assistance or financial support payments.
  5. Unemployment compensation.
  6. Strike benefits.
  7. Worker's compensation.
  8. Payments from pension, retirement, annuities from the government, military, veteran’s agencies or private companies.
  9. Funds received from alimony, child support, dividends or interest.
  10. Funds withdrawn from an estate or trust account in which funds are readily available to the family.
  11. Regular contributions from persons not living in the household, such as parental assistance to students.
  12. Monetary prizes.
  13. Withdrawal of funds from a savings or investment account.
  14. Student financial assistance, except those grants and scholarships excluded from income including Pell Grants, Student Incentive Grants and Direct Student Loans. Refer to 2023 7 CFR 246.4 (B)(8)(i).
  15. Funds received from capital gains and net royalties.
  16. Lump sum payments that are not reimbursements for lost assets or injuries (e.g., gifts, inheritance, lottery winnings, winnings and proceeds from gaming, gambling, bingo and severance pay). These payments shall be counted as annual income, not current monthly income.
  17. Income from work as a census worker or election official.
8. Income exclusions:
  1. The value of in-kind housing or other non-monetary benefits and bartered service.
  2. Federal and state tax refunds, Earned Income Tax Credit (EITC) and rebates.
  3. Gifts that are provided periodically.
  4. Loans, not including amounts to which the applicant has constant or unlimited access.
  5. Reimbursements for expenses incurred (e.g., business expenses and medical bills).
  6. Lump sum payments or large cash settlements received by the household as reimbursements for lost assets or injuries.
  7. Student financial assistance that meets all of the following criteria:
    1. Funds used to pay for costs of attending the institution at least halftime, but not for room and board or dependent care. Institutional attendance costs include tuition and fees, books and supplies, transportation and miscellaneous personal expenses for the student.
  8. Student financial assistance received from any program funded in whole or part under Title IV of the Higher Education Act of 1965 which include:
    1. Pell Grants.
    2. Supplemental Educational Opportunity Grant.
    3. Stafford Loans (currently referred to as direct unsubsidized and direct subsidized loans).
    4. Perkins Loans (disbursement ended in 2018).
    5. PLUS loans/supplemental loans for students (referred to as William D. Ford Federal Direct Loans [FFEL]).
    6. College work study.
    7. Byrd Honors Scholarship programs (disbursement ended in 2010).
  9. Volunteer payments through:
    1. Title I (Volunteers in Service to America (VISTA) and others) and Title II (Retired and Senior Volunteer Program (RSVP), foster grandparents and others) of the Domestic Volunteer Service Act of 1973.
    2. Section 8(b)(1)(B) of the Small Business Act (Service Corps of Retired Executives (SCORE) and Active Corps of Executives (ACE).
  10. Payments through:
    1. Migrant and seasonal farm workers programs.
    2. Veterans employment programs.
    3. Job Corps.
    4. Housing and Urban Development (HUD) rent subsidies.
    5. The Uniform Relocation Assistance and Real Property Acquisition Policies Act of 1970 as amended in 1987. This is for persons displaced from their homes by federal or state projects.
    6. The Civil Liberties Act of 1988 (Japanese internment camps).
    7. Dislocated worker programs.
    8. The prescription drug discount card program.
    9. Payments received by property owners under the National Flood Insurance Program (NFIP) for flood mitigation activities.
  11. Filipino Veterans Equity Compensation Fund payments.
  12. Cash stipend from the Division of Developmental Disabilities for purchasing goods and services for a family member with a developmental disability.
  13. The value of assistance to children or their families under the:
    1. National School Lunch Act.
    2. Child Nutrition Act of 1966.
    3. Food and Nutrition Act of 2008.
  14. Benefits received through childcare grant programs under:
    1. Section 402(g)(1)(E) of the Social Security Act, as amended by the Family Support Act.
    2. Child Care and Development Block Grant Act.
Military
1. Income inclusions for military:
  1. Military housing allowance, if assigned to a high cost-of-living area in the continental United States (Continental United States Cost-Of-Living Allowance or CONUS COLA).
  2. Basic Allowance for Subsistence (BAS) pay for military families.
  3. Income for military members from Deployment Extension Incentive Pay (DEIP)/Deployment Extension Stabilization Program (DESP) is included when the service member is serving at their home station in the United States. Refer to 2023 7 CFR 246.4 (C)(2)(d).
  4. Combat pay received by the service member prior to his or her deployment to or service in a designated combat zone.
2. Income exclusions for military:
  1. Housing allowances for military service personnel:
    1. The basic allowance for housing (BAH) received by military families living in the United States. This includes payments for both off-base housing and for privatized on-base housing.
    2. Family separation housing (FSH) provided to military personnel in overseas housing with military families continuing to receive BAH in the United States.
    3. Overseas housing allowance (OHA) provided to military personnel living overseas.
  2. The cost of living allowance the family receives when the military member is assigned and lives overseas, but the family (participant) lives within the United States. This is referred to as Overseas Continental United States Cost-Of-Living Allowance (OCONUS COLA).
  3. Combat pay received by military service personnel during deployment if:
    1. Received in addition to the service member's basic pay.
    2. Received as a result of the service member's deployment to or service in an area that has been designated as a combat zone.
    3. There are two categories of entitlement that are typically considered to be combat pay and are easily recognizable on the service member’s LES: Hostile Fire Pay/Imminent Danger Pay (HFP/IDP) and Hardship Duty Pay (HDP). However, other types of pay could be excluded if they meet the criteria above in i. and ii.
  4. Income for military members from DEIP/DESP while the service member is deployed overseas is to be excluded from the income assessment.
  5. Family Subsistence Supplemental Allowance (FSSA) payments provided by Department of Defense to low-income members of the Armed Forces.
Reassessing income
1. The LA must reassess a participant's income eligibility during the current certification period if the LA receives information indicating that the participant's household income has changed. However, such assessments are not required in cases where sufficient time does not exist to effect the change. Sufficient time means 90 days or less before the expiration of the certification period.
  1. The LA will ensure that such participants and other household members currently receiving WIC benefits are disqualified during a certification period only after their income eligibility has been reassessed based on the income screening procedures used for applicants who are not adjunctively eligible.
    1. Adjunctively eligible WIC participants may not be disqualified from the WIC program solely because they, or certain family members, no longer participate in adjunctively eligible programs.
    2. The LA must disqualify a participant and any other household members currently receiving WIC benefits who are determined ineligible based on the mid-certification income reassessment. Assess income eligibility using procedures outlined in part B. above.
  2. The LA shall issue the remaining benefits if there is less than 90 days remaining within a certification. Refer to policy 8.1.170 for ineligibility procedures.
Exceptions and zero income
1. The LA shall prompt applicants declaring zero income to describe in detail their living circumstances and how they obtain basic living necessities such as food, shelter, medical care and clothing, in order to apply WIC rules pertaining to family size and income properly.
  1. Exceptions
    1. Examples of individuals for whom the necessary documentation is not available include those with no income or no proof of income (such as an applicant or applicant's parent who is a migrant farmworker or other individual who works for cash). These are the only exceptions that may be used.
    2. The LA must require the applicant to sign an attestation statement specifying why they cannot provide documentation of income. This statement must be signed and scanned into the applicant’s file in MOWINS.
2. Self-declaring income is only applicable to adjunctively eligible applicants. All other applicants reporting zero income must complete the following:
  1. Zero Income Affidavit
    1. Applicants who report zero income must sign the zero income affidavit.
    2. Zero income shall be documented in MOWINS and the signed affidavit scanned into the applicant’s file.
3. Contact the district administrative TA for any additional questions regarding exceptions and zero income.

8.1.140 Determining Household Size

Authority: 2019 7 CFR 246.2, 246.7(d) & (h), WIC Policy Memo 99-4, FNS Instruction 803- 3, WIC Policy Memo 2013-3

Issued: 07/2019

Revised:

Policy:

The local agency (LA) shall determine income eligibility (See policy 3.02000.) of all applicants at each certification. The LA staff must interview the applicant to determine the household size to ensure proper income eligibility determination.

The LA shall reassess and verify WIC participant income eligibility during the current certification period if the LA receives information that the household size has changed. Reassessment of income eligibility is not required when 90 days or less remains in the current certification period.

Procedures:

For the purpose of determining household size, the words household, family, and economic unit can be used interchangeably to refer to a person or number of persons who usually live together (although not necessarily) and share economic resources and consumption of goods or services.
To be a household a family or individual, including a minor, must have its own source of income.
Two separate households may reside in the same residence if their production of income and consumption of goods are not shared. Shelter received from another does not have to be considered in determining shared income, food, and resources. It is possible to establish that more than one household lives in one residence through appropriate questioning which helps to make a reasonable determination that there is general economic independence of the households (i.e., both households have their own income and pay a proportionate share of household, living, and personal expenses).
Special circumstances:
1. Pregnant women may be counted as two persons in the household.
  1. The household size should not be automatically increased. Household size should only be increased if the pregnant woman did not meet the income guidelines during the initial determination.
  2. The pregnant woman must be given the option to deny the increase in household size for religious, cultural, or other reasons.
  3. An increase in household size for a pregnant woman must be documented electronically in the participant folder because it affects the income eligibility determination.
2. Children living with someone other than their parents or legal guardians:
  1. A child is generally considered a member of the household in which he or she is residing.
  2. Foster child
    A foster child is considered a separate household from the foster family if the child remains the legal responsibility of the court or other agency. A foster child is considered a household of one.
  3. Adopted child
    An adopted child or a child for whom a family has accepted legal responsibility is considered a member of the household in which he or she resides.
  4. Divorced families
    A child can be counted as a member of only one household. Children are considered a member of the household of the parent or guardian who has legal custody. When custody of a child is shared, the child shall be considered a member of the household in which he or she lives a majority of the time (i.e., more than 50 percent). When a child lives with each parent or guardian 50 percent of the time, the child shall be considered a member of the household of the parent or guardian who applies for WIC services first.
  5. Separated families
    An absent parent will not be considered part of the household if the other parent is receiving no monetary support.
  6. Institutionalized persons
    An individual or family residing in an institution is a separate household from others living in the same institution. If a parent is paying the support of a child residing in an institution, the child is counted as a member of the household.
  7. Military personnel
    Military personnel serving overseas or assigned to a military base, even though they are not living with their families are considered members of the household.
    Children in the temporary care of friends or relatives as a result of military service personnel being deployed overseas should choose one of the following options that best suits the situation of the WIC participant:
    1. Count the deployed parent(s) and the children as one household as would have been the case prior to the deployment.
    2. Count the children as a separate household.
    3. Consider the children to be part of the household of the person(s) with whom they reside.
3. Students
  1. Students temporarily away at school are counted as members of the household if the family provides support.
  2. A student who is temporarily away at school receiving no support from parents is considered to be living as a separate household.

8.1.150 Voter Registration

Authority: PL 103-31 (National Voter Registration Act of 1993 (NVRA)), Section 115.162 RSMo, WC-94-22-P, and WC-95-01-P

Issued: 10/2009

Revised: 04/2017

Policy:

The local agency (LA) shall provide adult applicants, participants and authorized representatives with the opportunity to register to vote at certification, recertification and any time a change of address is reported.

The LA shall document "register to vote" status in MOWINS at certification, recertification and any time a change of address is reported.

The LA shall retain the voter registration tally sheet and original/copy of the declination forms for 24 months.

Procedures:

The LA shall offer voter registration services to individuals who are at least 17½ years of age applying for WIC benefits for themselves or on behalf of an infant or child (in which case, he or she acts as an authorized representative) at certification, recertification and when reporting name or address change. The LA staff shall notify the participants/authorized representatives that applying or not applying to register to vote will not affect their WIC benefits. The LA shall also provide voter registration applications to any persons present in the office who request them.
1. The LA staff must orally ask the participants/authorized representatives "if you are not registered to vote where you live now, would you like to apply to register to vote here today?" The LA must complete or update the "Register to Vote" feature in the demographics screen in MOWINS by checking one of the responses in the drop down box a) Selected to register, b) Declined or ineligible to register or c) Already registered and provide the application to the participant(s)/authorized representatives who wish to register.
2. For participants/authorized representatives who respond "yes, I want to register", or when the participant reports a change of name and/or address, the LA staff will ensure the participant/authorized representative checks the "YES" box on the back of the Missouri Voter Registration Application (also referred to as the declination section of the application). Make a copy of the back page of the form for the agency's central file, and give the participants/authorized representatives the Missouri Voter Registration Application.
  1. Encourage the participants/authorized representatives to complete the application on-site. The participants/authorized representatives may take the registration application home to complete and mail the completed application directly to their local election authority or bring the completed application to the LA at their next clinic visit.
  2. LA staff must provide the same amount of assistance to an individual completing the voter registration application as they would to an individual completing the WIC forms.
  3. Inform the participants/authorized representatives that registration approval notification will be mailed to them from their respective local election authority.
  4. The participants/authorized representatives must fill in all boxes on the Missouri Voter Registration Application. The LA staff should review the application to ensure that it is complete and legible.
3. For participants/authorized representatives who respond that they do not wish to register or simply state "no" or "no, I am already registered", the LA staff will assure the participants/authorized representatives check the correct box (either "NO" or "NO, already registered at current address") on the back of the Missouri Voter Registration Application. The participants/authorized representatives must sign on the designated space on the back of the declination section of the form. If the participants/authorized representatives refuse to sign, the LA staff shall put "declined to declare", then initial and date. Keep the original signed forms in the agency's central file.
4. For participants/authorized representatives who indicate that they do not want to register to vote because they are ineligible or for any reason, the LA staff will assure the participants/authorized representatives check the "NO" box at the back of the Missouri Voter Registration Application. The participants/authorized representatives must sign on the designated space on the back of the declination section of the form. If the participants/authorized representatives refuse to sign, the LA staff shall put "declined to declare", then initial and date. Keep the original signed forms in the agency's central file.
5. For participants/authorized representatives who decline to mark any box, the LA staff will record on the declination form the date and the fact that s/he declined to declare a preference regarding voter registration services. The LA staff will sign the form.
6. The LA shall forward all completed applications with "YES" response to the proper local election authority weekly based on each participant’s address. Contact person and mailing address for each local election authority can be found at the Missouri Secretary of State web page. Mailing costs associated with transmission of the registration applications to the local election authority are allowable WIC costs. Voter registration applications may be delivered to the local election authority in person, rather than mailed. The LA does not need to make copies of the completed applications. The LA shall keep a tally on the form located here that will include: the total number of voter registration applications sent to the proper local election authority’s office weekly (within 5 days), which local election authority the applications were sent to (list by county only e.g. St. Louis City or St. Louis County), the date the applications were sent to the local election authority and the initials of the sending staff. Enter zero (0) on the tally sheet for the week(s) that the LA do not receive any completed applications. This tally sheet shall be maintained for monitoring purposes.
7. Participants/authorized representatives must be offered Voter Registration services even when the previous certification shows they are already registered to vote. This is an opportunity to ask about and document changes in address, name, etc.
8. A flow chart detailing the steps required to comply with the NVRA and this policy is attached.
LAs are encouraged to continue to make voter registration applications available in public areas such as waiting rooms.
The LA staff must not:
1. Attempt to influence a participant's political preference or party registration;
2. Display any information or literature on political or party affiliation;
3. Attempt to discourage a participant from registering to vote; and
4. Lead the participant to believe that the decision to register or not register to vote will affect the availability of program services or benefits.
The terms of the policy will be integrated into the WIC clinic in a manner that minimizes burden and is least disruptive to WIC program procedures.
The SA shall provide training materials to the LA in order to ensure uniform application of the law and this policy. The LA shall assure new employees can competently perform all duties related to voter registration at the time they are required to perform them. The LA is required to provide designated new staff with NVRA training within six (6) months of the date of hire or rehire. The LA must also train designated staff annually using the provided training materials. Refer to 2.4.010 for LA training documentation requirements.
The WIC Coordinator shall act as the NVRA liaison or appoint a staff member to act as the NVRA liaison with the local election authority in their service area. The WIC NVRA liaison shall be responsible for training new employees, periodically observing clinic staff to ensure the requirements of NVRA are understood and met and ensuring an adequate (e.g., 4 month) supply of registration applications are available at all clinic sites. The LA must use the Missouri Voter Registration Application provided by the State. Additional applications can be ordered from the DHSS warehouse.
The LA must retain the voter registration tally sheet and the original/copies of the declaration section of the applications in the agency's central file for 24 months. The LA should file the declination sections of the application by month.
The SA shall oversee and monitor LAs for compliance with the NVRA and the provisions of this policy. For the SA's monitoring policy and procedures refer to 10.1.030.
1. The SA will review the tally sheets and declination forms during the on-site monitoring visit.
2. At any time, the SA can request a tally of the application and responses to the declination forms for any month. The LA will have 15 business days to provide the tally.
3. MOWINS will include a "Register to Vote" feature in the demographics screen, as described in A1 of this policy. LA staff may not bypass the voter registration question; the voter registration question must be answered in order to proceed with certification/recertification.
The National Voter Registration Act implementation guide can be found on the Secretary of State website.

8.1.160 Transfer of Certification and Verification of Certification (VOC)

Authority: 2016 7 CFR 246.7(k), 7 CFR 246.26(d)(l)(ii), WIC Policy Memo2016-4 Verification of Certification

Issued: 12/1989

Revised: 02/2017

Policy:

To ensure continuation of program benefits and to prevent dual participation, a Verification of Certification (VOC) shall be issued to a participant who is relocating to another state, or is likely to be relocating, during an active certification period. Migrant farm workers and military households are common examples of participants who may need a VOC.

The local agencies (LA) shall respond as soon as possible to a request for transfer from an active WIC participant or a WIC agency from another state. A single point of contact, WIC Help Desk 800-554-2544 or WICHelpDesk@health.mo.gov, has been established for other State or local agencies to use to obtain VOC information. Point of contact information for other states can be found at the USDA website to request information or a VOC from another state or military facility.

A participant who arrives at an LA (the receiving agency) with a valid VOC must be transferred and allowed to continue participating through the end of his/her current certification period, even if the participant does not meet the receiving agency’s nutritional risk, priority or income criteria. If the receiving LA has a waiting list for participation, the transferring participant shall be placed on the list ahead of all other waiting applicants.

Procedures:

Transfer Out (Sending Agency)

Local agencies shall routinely ask participants if they plan to move during the certification period, describe the VOC availability and process in the Rights and Responsibilities Statement, and post signs reminding participants to ask for a VOC if they are going to be moving before their next appointment. When a participant or guardian informs the LA of a move out of the agency service area, the agency shall inquire whether the move is within Missouri or outside of Missouri. Local agencies are required to provide a VOC to all migrant families, and any other participant who is likely to relocate during a certification period.
If the move is outside of Missouri, the following steps will be taken:
1. A Verification of Certification (VOC) will be printed from MOWINS, signed by the LA staff and given to the participant. The Verification of Certification shall include the following eight items:
  1. Name of the participant.
  2. Date the certification was performed.
  3. Date income eligibility was last determined.
  4. Nutritional risk condition of the participant.
  5. Date the certification period expires.
  6. Signature and printed or typed name of the certifying LA official.
  7. Name, address and phone number of the certifying LA.
  8. An identification number or some other means of accountability. If proof of income is “Pending” in the participant’s chart, the LA must write “Pending proof of income” on the transferring out VOC.
2. If the participant moves outside Missouri without notifying the Missouri LA, the LA shall mail or send by secure fax the VOC to the requesting participant or the receiving WIC agency. The LA shall not require the participant to sign a release of information to share VOC information with the receiving agency. The LA may request the receiving agency fax the written request on the agency’s letterhead, in order to verify it is another LA requesting the VOC information.
3. If applicable, ensure appropriate measures are taken to collect loaned breast pumps included in the agency’s equipment inventory.
4. If the participant is receiving Food Package III, the medical documentation form (WIC 27) should be printed and sent with the participant.
5. The participant is automatically terminated from MOWINS.
If the move is within Missouri, give the participant or guardian the contact information about the LA closest to his/her new home. Include the LA name, address, and phone number (refer to https://health.mo.gov/living/families/wic/locations.php).

Transfer In (Receiving Agency)

When a participant or guardian contacts the LA to find out about transferring into the agency, the LA shall inquire whether the transfer is within or outside of Missouri.
1. If the transfer is from another state WIC program, the following steps will be taken:
  1. If the participant is not in an active certification period, treat the participant as new.
  2. If the participant has a VOC for an active certification period,
    1. The LA must complete a statewide search in MOWINS prior to entering participant(s) records in the system as a VOC certification.
      The VOC is valid until the certification period expires, and shall be accepted as proof of eligibility for Program benefits. If a transferring participant presents a VOC that is missing one or more of the required components, the participant must not be penalized, nor services delayed, for the failure of a sending agency to properly include the required components. Therefore, a VOC is considered valid if it contains the following three items: 1) the participant’s name; 2) the date of certification; and 3) the date that the current certification expires. A transferring participant who presents a VOC with at least these three pieces of information must be treated as if the VOC contains all the required information.
      If a nutritional risk is not recorded on the VOC or if the participant was certified based on a nutrition risk condition not used by the receiving agency, the receiving agency must use risk code 502 “Transfer of Certification” to establish nutritional risk for that participant.
      When a transferring participant presents without a VOC, or with insufficient information on a VOC, the receiving agency is encouraged to contact the sending agency to retrieve missing information (USDA FNS point of contact information to request information or a VOC is http://www.fns.usda.gov/wic/wic-contacts). The VOC end date cannot be extended.
    2. Enter the participant’s records in the data system as a VOC certification, update demographics, and offer voter registration. While a VOC is considered sufficient proof of income and nutritional risk eligibility, transferring participants must provide proof of identity and current residency to the receiving agency. If proof of identity and residency are not immediately available, the LA may accept a written statement from the participant and scan it into the participant’s chart in MOWINS. Update demographics accordingly and offer voter registration.
    3. If a VOC is presented to a receiving agency and the certification will expire soon (within the next 30 days), the receiving agency may conduct recertification for the convenience of the participant. If the participant’s category changes prior to the end date on the VOC, the participant should be reassessed to receive benefits. For all postpartum women and infants, the Health Information tab must be updated; this includes the participant link(s) and the amount of breastfeeding.
    4. Assign the same Food Instrument (FI) issuance cycle as stated in the VOC document (monthly, bi-monthly, tri-monthly). If the FI cycle is not stated on the VOC, the LA should determine the food instrument cycle based on nutritional risk.
    5. Scan the VOC in MOWINS and return the VOC to the participant or shred it.
    6. Refer to 2.04910, Risk Factor 502 Transfer of Certification, for risk factor assignment information.
    7. If the participant has food instruments from another state WIC program, the receiving agency must destroy the unused food instruments or EBT card from the transferring participant. The LA will need to prorate the food package based on the amount of benefits redeemed. This information should be retrieved from the sending agency or that State’s point of contact. Point of Contact information for other states can be found on the USDA FNS website (http://www.fns.usda.gov/wic/wic-contacts). If there are any issues concerning lost checks or EBT cards, contact the sending agency or the SA point of contact (http://wwwfns.usda.gov/wic/wic-contacts).
    8. If the infant is on a contract formula, the same formula will be issued.
    9. If the infant is on a non-contract formula, a comparable contract formula will be issued. WIC staff must explain the differences in supplemental food packages including differences in formula.
    10. If the participant is on Food Package III and the participant has medical documentation that has been approved from the sending agency and the exempt formula/medical food is in the Food and Formula Reference Guide, the exempt formula/medical food will be issued for the length indicated on the medical documentation form up to 6 months duration.
      
      Note: If the participant states they are on an exempt formula/medical food and do not have the approved medical documentation form, the agency shall contact the sending agency or the SA point of contact (http://www.fns.usda.gov/wic/wic-contacts) and have the approved medical documentation provided. Exempt formula/medical food can be issued for one month while the medical documentation is obtained from the sending agency. The medical documentation form shall be scanned into MOWINS. If the medical documentation form is not obtained from the sending agency, a new WIC 27 shall be obtained from a medical provider.
2. If the transfer is from another LA in Missouri, any LA staff can access the transfer feature of MOWINS and transfer each participant in the household to their agency.
  1. Schedule an appointment for the participant to return:
    1. In the same month if food instruments are due, or
    2. Next month if food instruments are not due.
  2. If the participant has food instruments from the previous agency that are not expired, the participant can keep and use the FIs. If the FIs are expired, collect the FIs and deface them.
    1. For participants transferring from Labor Delivery Recovery Postpartum (LDRP – Hospital setting) refer to 8.1.070 and 9.1.020.
  3. The receiving LA should call/e-mail the LA that the participant transfers from to notify them that the participant has been transferred out of their agency. Include the participant's name and state WIC ID number.

8.1.170 Notification of Ineligibility, Termination, or Expiration of Certification

Authority: 2019 7 CFR 246.7(h)(1), (j)(2), (5), (6), and (8); 7 CFR 246.9(a) and (g), FNS Instruction 803-9, Rev. 1

Issued: 01/1981

Revised: 02/2020

Policy:

The local agency (LA) shall give an applicant, participant, authorized representative, or proxy a written notice of the reason for program ineligibility and the right to a fair hearing.

The LA shall give notice to a participant, authorized representative, or proxy when their certification is about to expire.

Procedures:

A written notice of ineligibility is required for the following:
1. The applicant or participant is not at a nutritional risk.
2. The applicant or participant exceeds WIC program income guidelines and is not adjunctively eligible for services.
3. The applicant or participant does not live, work, or receive health care in Missouri.
4. The applicant or participant is not categorically eligible.
When an applicant or participant is determined ineligible at a certification, the LA shall:
1. Complete and provide the WIC Notification of Ineligibility or Termination form (WIC 19) or provide the notification generated from the Missouri WIC Information Network System (MOWINS). The LA must scan a copy into MOWINS. Refer to policy 11.1.030.
2. Inform the applicant or participant food benefits will not be provided due to ineligibility.
When a participant is determined ineligible during a certification period, the participant must be advised at least 15 days prior to termination. The LA shall complete and provide the WIC Notification of Ineligibility or Termination form (WIC 19). Refer to policy 11.1.030.
When a participant is nearing the expiration of a certification period, the participant must be advised at least 15 days, but no more than 60 days, prior to expiration. The LA must provide notification of expiration by providing the participant the notice printed on the eWIC Shopping List or Account Balance.

8.1.180 Schedule Certification Periods

Authority: 7 CFR 246.7(g);

Issued: 01/1981

Revised: 10/2015

Policy:

The local agency (LA) shall use the certification and mid-certification assessment (MCA) periods established by the MOWINS data system.

Procedures:

The MOWINS data system will automatically calculate the certification and MCA dates according to program categories as follows:
1. Prenatal women
  1. Prenatal women are eligible for certification through the last day of the month in which the infant turns 6 weeks old or the pregnancy ends.
  2. A MCA is not required for prenatal women.
2. Breastfeeding women
  1. Breastfeeding women are eligible for certification for up to one year postpartum, or until the woman stops breastfeeding, whichever occurs first.
    1. The MCA date is set by MOWINS to be 6 months after the certification effective date.
    2. The MCA may be completed up to 60 days prior to the MCA date.
    3. The MCA shall be completed no later than the last day of the certification period.
    4. A MCA is not required for breastfeeding women certified after 6 months postpartum.
3. Non-Breastfeeding women
  1. Non-Breastfeeding women are not eligible for certification beyond six months postpartum, therefore, the end certification date must be shown as the last day of the sixth month after the baby is born or the last day of the sixth month after the pregnancy ends.
  2. A MCA is not required for non-breastfeeding women.
4. Infants
  1. Infants from birth to 6 months of age are eligible for certification for a period extending up to the end of the month of the first birthday.
    1. The MCA date is set by MOWINS to be 6 months after the date of birth.
    2. ii. The MCA may be completed up to 60 days prior to the MCA date as long as the infant is at least 6 months of age.
    3. The MCA shall be completed no later than the last day of the infant’s 11th month.
  2. Infants older than 6 months of age are eligible for certification for the next six months and appropriate food package and status changes shall be made at 1 year of age.
    1. A MCA is not required.
5. Children
  1. Children are eligible for certification at twelve (12) month intervals. Exception: the child is terminated at the end of the month in which the child has the fifth birthday.
    1. The MCA date is set by MOWINS to be 6 months after the certification effective date.
    2. The MCA may be completed up to 60 days prior to the MCA date.
    3. The MCA shall be completed no later than the last day of the certification period.
Extending or shortening certification periods by 30 days.
1. In cases where there is difficulty scheduling appointments, the certification time may vary plus or minus 30 days from the certification due date. The new certification due date would be calculated in the manner described in A.1 through A.5.
2. The following guidelines apply to extending or shortening certification periods:
  1. Prenatal-do not shorten or extend.
  2. Breastfeeding-do not shorten or extend.
  3. Non-breastfeeding-do not shorten or extend.
  4. Infant certified at age six (6) months or less-do not shorten, can extend.
  5. Infant certified over age six (6) months-can shorten or extend. (Note: shall not shorten if would bring the infant in at less than one year of age.) f. Children-can shorten or extend, but never beyond the end of the month of the fifth (5th) birthday.
3. Certification periods cannot be adjusted to give extra time to participants who miss scheduled certification appointments.
4. When certification periods are shortened or extended, subsequent certification dates will be based on the date when certification is entered into MOWINS.
5. A subsequent certification should be completed during the last 30 days of the current certification period for participants on intervals of 12 months to assure proper notification. Refer to 8.1.170.

8.1.190 Authorized Representatives and Alternate Representatives

Authority: 2019 7 CFR 246.7(c)(2)(i), 246.12(r)

Issued: 03/1983

Revised: 02/2020

Policy:

An authorized representative is a participant or the parent, legal guardian, or caretaker of a participant. The authorized representative is responsible for providing proof of identity, residency, and income; attending appointments; completing paperwork; participating in nutrition education; and redeeming benefits at the retailer.

The parent, legal guardian, or caretaker who brings in an infant or child for their first appointment is the authorized representative and can designate up to two (2) alternate representatives, or two (2) proxies, or one of each.

The authorized representative signs the WIC Participant’s Rights and Responsibilities (WIC-10). Refer to policy 8.1.080.

The alternate representative is a parent or caretaker for an infant or child participant and may attend certification appointments when the authorized representative is not available.

Regardless of age, a parent of a participant may be designated as the authorized representative or alternate representative for their infant or child.

Procedures:

Assigning an authorized representative:
1. The following person(s) may apply for benefits on behalf of an infant or child under five years of age:
  1. Natural mothers or fathers, if the child is living with them.
  2. Guardians or foster parents who are legally responsible for the care and management of the infant or child. Legal documents should be used to verify the guardianship status of the child.
  3. Relative or other caretaker with whom the child is living if they have written verification. This verification can be a letter from a natural parent or documentation from the Department of Social Services (DSS) granting kinship and identifying that the infant or child is living with this person.
The LA shall not change the authorized representative unless one of the following conditions apply:
1. The current authorized representative sends a signed and dated statement requesting the authorized representative be changed. The local agency (LA) may then change the authorized representative with accompanying proof of identification. Proof of residence and income must be shown if the participant has moved and/or the household size has changed. Refer to policy 8.1.140.
2. Change in custody: If at any time a caretaker arrives at the clinic with legal proof of full (100%) custody of an infant or child participant, staff may change the authorized representative with accompanying proof of identity, residency, and income information.
  1. It is the responsibility of the caretakers who share 50 percent custody to determine who will be the authorized representative.
  2. Clinic staff will not be involved in making decisions as to who will be the participant’s authorized representative.
3. Foster care: When a child is placed in foster care, the foster parent becomes the authorized representative with proof of custody from the DSS. If the foster parent changes, the new foster parent becomes the authorized representative with legal proof of custody.
The authorized representative may change the alternate representative at certification. If the change needs to occur during the certification period, the authorized representative shall complete the Proxy/Alternative Authorized Representative Form (WIC-33).
An authorized representative may receive copies of participant information for themselves or the participant for whom they are caring. Refer to policy 8.1.010.

8.1.200 Proxies

Authority: 2019 7 CFR 246.2, 246.7(c)(2)(i), 246.12(r)

Issued: 03/1983

Revised: 02/2020

Policy:

The local agency (LA) shall allow the authorized representative to designate a proxy. An authorized representative is a woman participant or a parent, legal guardian, or caretaker who is applying for benefits on behalf of a child or infant. Refer to policy 8.1.190.

A proxy is a person designated by the authorized representative to obtain and transact food benefits on behalf of a participant.

The LA shall require proof of identity from the proxy before the issuance of food benefits. Refer to policy 8.1.210.

Authorized representatives should be advised to designate only a responsible and trustworthy person to be a proxy.

The authorized representative may change the proxy at any time.

Procedures:

Designating proxies:
1. The LA shall ask the authorized representative for a proxy designation at certification. The LA shall document the name and choose the proxy designation in the relationship dropdown.
2. If the authorized representative chooses to add or make a change to the proxy designation during the certification period, the authorized representative must make the request in person or in writing. The new proxy must provide proof of identity prior to receiving food benefits on behalf of the authorized representative or participant.
  1. If the authorized representative is not able to be present, he or she may send a signed note with the new proxy’s name. The LA will scan the note into MOWINS and enter the new proxy’s name in MOWINS.
  2. If a change of proxy is requested by phone, LA staff shall verify they are speaking to the authorized representative by askingfor date of birth or address. LA staff must enter a general note regarding the change and update MOWINS with the name of the new proxy.
  3. If LA staff are unable to verify they are speaking to the authorized representative, they should request a signed note from the authorized representative be sent with the new proxy.
A proxy must comply with program regulations.
1. The authorized representative will be held responsible to educate the proxy on how to use the food instrument and how to select allowable WIC foods.
2. Any program violation by a proxy may result in the authorized representative or participant’s ineligibility or removal from the program. The participant or authorized representative and the proxy may be subject to civil or criminal prosecution.
LA staff must ensure that proxies are notified that they have a right to submit complaints about improper retailer practices.
An authorized representative may give the food instrument and personal identification number (PIN) to someone that is not listed as a proxy in MOWINS. This individual is not authorized to attend appointments at the LA but may go to the retailer to purchase the WIC foods for the participant. The authorized representative must be aware that any individual given the PIN must comply with program regulations the same as an authorized representative. Any program violation by anyone who has been given the PIN may result in participant ineligibility or removal from the program. The participant or authorized representative of an infant or child, and the person who was given the PIN, may be subject to civil or criminal prosecution.
LA staff must not serve as a proxy unless a signed note from the authorized representative naming the staff as a proxy is on file for the current certification period. Refer to policy 8.1.030.

8.1.210 Identity Requirements

Effective: 05/01/2025

Issued: 10/1999

Authority references: 2025 7 CFR 246.7(c)(2)(i); 246.7(i)(4); WIC policy memo 99-4; WIC policy memo 2016-4; ARPA Physical Presence Waiver 2023; WIC policy memo 2023-6

Policy:

The local agency (LA) must verify and document the identity of each applicant, participant, authorized representative, alternate representative and proxy for WIC services, including, but not limited to, nutrition assessment, nutrition education and food instrument/food benefit issuance.

Procedures:

Identity requirements.
1. The LA must verify identity using the proof of identity documentation options listed within this policy before providing WIC services, food instruments and food benefits, regardless of the service delivery method (e.g., remote or in-person). Refer to policies 1.1.030, 2.4.110, 8.1.070 and 8.1.280.
2. The LA must verify the identity of the applicant or participant and any individual receiving WIC services on behalf of the applicant or participant.
  1. The LA must inform individuals that proof of identity must be provided for the applicant, participant, authorized representative or alternate representative at the appointment when scheduling initial certification and subsequent certification appointments.
  2. For applicants, authorized representatives or alternate representatives who do not bring proof of identity documentation to their certification appointment, refer to policy 8.1.270.
3. Proof of identity documentation:
  1. Must be provided by the authorized or alternate representative.
  2. May be documentation from another country.
  3. Must originate from an outside source that is not WIC.
    1. WIC staff cannot generate proof of identity documentation for participants or applicants (e.g., photos or immunization records).
  4. May be provided in person, by mail or sent to the clinic via secured electronic means. Refer to policy 8.1.010.
4. Exceptions:
  1. Disaster, homeless or migrant considerations.
    1. The LA may authorize the certification of applicants without proof of identity documentation, such as victims of theft, loss or disaster, homeless individuals or migrant individuals. In these cases, the applicant must sign a statement attesting to their identity and explain why proof of identity documentation cannot be provided.
    2. If the LA becomes aware that proof of identity documentation is available within a certification period, it must be requested if an exception (i.e., signed statement) was utilized at the certification appointment.
      1. The participant must continue to receive benefits during the certification period.
5. The LA must request proof of identity documentation when a WIC participant is transferring to Missouri from another state. A Verification of Certification (VOC) does not document proof of identity. Refer to policy 8.1.160.
Initial certifications.
1. Acceptable proof of identity documentation for the initial certification includes the following:
  1. Infants and children:
    1. Birth certificate.
    2. Social security card.
    3. Hospital record.
    4. Immunization record. Provided by the authorized or alternate representative.
    5. Social services benefit letter.
    6. Naturalization papers.
    7. Health insurance or MO HealthNet card.
    8. Passport.
    9. Signed statement used for exceptions.
    10. Official school documents (e.g., school identification card).
    11. Foster care placement letter.
  2. Adults:
    1. Birth certificate.
    2. Driver license.
    3. Employee identification card.
    4. Foster care placement letter.
    5. Health insurance or MO HealthNet card.
    6. Hospital record.
    7. Pay stub that includes name, address and date.
    8. Immunization record.
    9. Military identification card.
    10. Naturalization papers.
    11. Social security card.
    12. Social services benefit letter.
    13. State-issued photo identification.
    14. Government-issued photo identification.
    15. Voter identification card.
    16. Official school documents (e.g., school identification card).
    17. Passport.
    18. School financial aid documents.
    19. Signed statement that is used for exceptions.
Subsequent certifications.
1. For subsequent certifications, the LA must use proof of identity documentation options listed in this section or options listed in part B above.
2. For in-person subsequent certifications, if acceptable photo identification has been retained within the Management Information System (MIS) as proof of identity documentation from a prior certification, it may be used to establish identity at a subsequent certification.
3. The WIC card may be used as proof of identity documentation at subsequent certifications. The LA must verify identity verbally by crossreferencing their name with that of an adult participant, authorized representative or alternate representative listed in the account. Request validation of the last four digits of the card number and at least two of the following details:
  1. The primary cardholder’s date of birth (DOB).
  2. The zip code of the household’s mailing address.
  3. The names of household members currently participating in WIC.
Other WIC appointments.
1. The LA must use proof of identity documentation options from part B or C to verify identity at all other WIC appointments and services.
Documenting proof of identity.
1. The LA must indicate and select the type of document viewed to provide proof of identity in the MIS.
2. If a signed statement is used for exceptions, the LA must select the exception option in the MIS and scan the signed statement into the participant's folder. Refer to policies 4.1.060 and 2.4.090.
  1. If proof of identity is provided later, document in a general note the type of proof documentation that was viewed.

8.1.240 WIC Shopping Assistant

Effective: 08/2024

Issued: 06/2023

Authority references: 2023 7 CFR 246.6(b)(3); 246.8; 246.25(a); 246.14(c); 246.26(d); WIC policy memo 95-2; FNS instruction 800-1

Policy:

The local agency (LA) may offer the services of a WIC shopping assistant to enhance and improve the WIC shopping experience. The WIC shopping assistant shall be available to support new and current WIC participants, authorized representatives, alternate representatives and proxies who express difficulties shopping for WIC foods, using the WIC card or utilizing the WICShopper app. This service is optional for LAs, provided they can meet staffing and training requirements. If the LA chooses to provide a WIC shopping assistant, this service shall be offered at all certifications and available to all WIC participants, authorized representatives, alternate representatives and proxies upon request.

Procedures:

Coordinating services
1. The WIC shopping assistant shall be a qualified individual with the proper knowledge, training and basic understanding of the WIC program. The duties of the WIC shopping assistant include, but are not limited to, the following:
  1. The WIC shopping assistant shall accompany the participant, authorized representative, alternate representative or proxy to their choice of retailer. The choice of retailer shall not, in any way, be influenced by the WIC shopping assistant or other LA staff.
  2. The WIC shopping assistant shall not influence or limit, in any way, WIC-approved food product choices while providing services.
  3. The WIC shopping assistant shall assist in locating and identifying WIC-approved foods at the retailer. All dietary or nutrition-related questions shall be referred to the LA WIC nutritionist or CPA.
  4. The WIC shopping assistant is not responsible for handling retailer issues and shall refer the participant, authorized representative, alternate representative or proxy to the LA for any retailer questions, concerns or complaints.
2. Promote utilization of the WICShopper app and WIC card.
  1. Explain the WICShopper app features while in the store to assist participants, authorized representatives, alternate representatives or proxies in obtaining full redemption of all WIC benefits.
  2. Assist with WIC transactions while at the register to ensure understanding of WIC card usage.
    1. The participant, authorized representative, alternate representative and proxy must handle the WIC card during transactions, including entering the personal identification number (PIN). The PIN is confidential information that is not to be shared with the WIC shopping assistant.
    2. The WIC shopping assistant shall not be required to troubleshoot WIC card issues. If troubleshooting is required, they shall be referred to the LA for further assistance.
  3. Ensure the WIC shopping assistant’s services are utilized during regular clinic hours.
    1. Services may be available to WIC participants, authorized representatives, alternate representatives or proxies who need assistance outside regular clinic hours. These services shall be determined on a case-by-case basis.
    2. WIC shopping assistant services shall be reported as client services for invoicing purposes.
  4. Interpretation services shall be available for WIC shopping assistant services as needed. Refer to policy 11.1.020.
  5. Participant information shall remain confidential at all times during the WIC shopping assistant’s services. Refer to policy 8.1.010.
Travel and reimbursement
1. Travel reimbursement for the WIC shopping assistant is allowable and shall be reimbursed according to LA's current travel policies and existing mileage reimbursement rates.
2. All travel should be tracked and documented daily for reimbursement purposes.
  1. Documentation should include the participant’s household ID number, date and time of the appointment with the WIC shopping assistant, retailer address and mileage.
3. The safety of the WIC shopping assistant is imperative. If at any time the WIC shopping assistant feels threatened or at risk of harm, the assistant has the right to terminate the appointment for any reason.
4. Meal reimbursement for the WIC shopping assistant is not an allowable cost.
Training and qualifications
1. Minimum qualifications/education:
  1. Possession of a high school diploma or equivalency.
  2. General knowledge of the WIC participant population and authorized Missouri WIC retailers in the LA service area.
2. LAs are responsible for providing the required state agency (SA) approved training to the WIC shopping assistant.
  1. Successful completion of the SA-required WIC training within the time frames outlined in policy 2.4.010.
  2. The LA shall maintain a copy of the WIC shopping assistant training record for monitoring purposes.
Tracking and documentation
1. The LA shall document each WIC shopping assistant session in the Management Information System (MIS).
  1. The date and time, retailer location and topics covered (i.e., WICShopper app, selection of WIC foods at the retailer or WIC card usage) shall be documented in the participant folder under the general notes tab.
2. LA staff shall follow up with each WIC participant, authorized representative, alternate representative or proxy within 30 days after utilization of the WIC shopping assistant’s services.
3. LAs shall have a mechanism to receive feedback and evaluate the ease of services.
4. LAs shall maintain complete records concerning the WIC shopping assistant program. Refer to policy 10.1.070.

8.1.260 Adjunct Eligibility Requirements

Effective: 10/2023

Issued: 06/2023

Authority references: 2023 7 CFR 246.4(a)(6); 246.7(d) and (h); WIC policy memo 93- 1; WIC policy Memo 99-4; WIC policy memo 99-6; WIC policy memo 2013-3; ARPA Physical Presence Waiver 2023; WIC policy memo 2023-6

Policy:

The local agency (LA) must assess adjunct eligibility before requiring additional documentation for an income eligibility determination.

The LA must verify adjunct eligibility information and/or documentation prior to the certification appointment.

Adjunct eligibility is income eligibility on the basis of an applicant's or certain family members' current eligibility to receive benefits under the Supplemental Nutrition Assistance Program (SNAP), Medicaid (MO HealthNet) or Temporary Assistance for Needy Families (TANF).

Procedures:

Assessing adjunct eligibility
1. The LA shall assess each applicant for adjunct eligibility at each certification. Verification of current participation in an adjunctively eligible program is required, and self-declaration is not acceptable.

Obtaining adjunct eligibility data

Electronic documentation for proof of adjunct eligibility may be provided in person or sent to the clinic via secured electronic means. Refer to policy 8.1.010.

Adjunct eligibility may be proven with the following:

The use of the Missouri Health Strategic Architectures and Information Cooperative (MOHSAIC) system showing current participation in MO HealthNet, SNAP or TANF.
1. The LA may use the current Medicaid eligibility (ME) codes provided in MOHSAIC to determine if the MO HealthNet program is adjunct eligible.
2. Alternative state agency (SA) approved methods may be used in order to determine eligibility.
Foster care placement letter.
TANF letter showing current eligibility.
SNAP program letter showing current eligibility. A SNAP EBT card is not acceptable proof of current eligibility.
The LA shall accept as income-eligible for the program any applicant who documents that he/she is a member of a family that is certified eligible to receive assistance under TANF, or a member of a family in which a pregnant woman or an infant is certified eligible to receive assistance under an eligible MO HealthNet ME code.

The LA shall assess individual adjunct eligibility and circumstances where adjunct eligibility automatically applies to all other categorically eligible family members.

Adjunct eligibility Table 1.

Program	Adjunct eligibility for the individual	Adjunct eligibility for categorically eligible household family members
SNAP	Yes	No
TANF	Yes	Yes
Infant with eligible MO HealthNet	Yes	Yes
Pregnant woman with eligible MO HealthNet	Yes	Yes
Child with eligible MO HealthNet	Yes	No
Breastfeeding (BF) postpartum woman with eligible MO HealthNet (until the infant is 6 months of age)	Yes	No
Non-BF postpartum woman with eligible MO HealthNet (until the infant is 6 months of age)	Yes	No

Refer to the MO HealthNet decision tree or your administrative district technical assistance staff (TA) for additional guidance.

Foster children
1. The adjunct eligibility of an infant or child in foster care does not confer adjunct eligibility to any other members of the foster family or household. Refer to policy 8.1.140.
2. Only funds received from the Division of Social Services (DSS) shall be included for the self-declared income of a foster child. Income from the foster family or household shall be excluded.
The LA shall utilize income assessment procedures if adjunct eligibility cannot be verified. Refer to policy 8.1.130.
Reassessing adjunct eligibility
1. The LA must reassess a participant's WIC program eligibility during the current certification period if the LA receives information indicating that the participant's adjunct eligibility has changed.
  1. However, such assessments are not required in cases where sufficient time does not exist to effect the change. Sufficient time means 90 days or less before the expiration of the certification period. Refer to policy 8.1.170.
  2. Adjunct eligibility reassessment shall be completed on an individual basis unless one or more household members have an eligible MO HealthNet plan for a pregnant woman, have an eligible MO HealthNet plan for an infant or actively receiving TANF.

Documenting adjunct eligibility
1. Document each individual departmental client number (DCN) in the corresponding participant folder.
2. An adjunctively eligible individual is not subject to further income assessment and shall self-declare their household income. Adjunct eligibility overrides actual income.
  1. The LA must document income and household size in MOWINS.
  2. The “self-declaration” option only applies to adjunctively eligible applicants or participants.
  3. If an applicant is not able to readily provide this information or declines to self-report their income, it must not interfere with their certification, nor result in collecting additional income documentation.
    1. Document the reported income or zero if they report no income or refuse to self-report their income.

8.1.270 Temporary Certification

Authority: 2023 7 CFR 246.7(c)(2)(i); 246.7(i)(4) and (5); WIC policy memo 99-4; FNS final rule 77245: Certification Integrity; WIC policy memo 2007-1; WIC policy memo 2013-3; ARPA Physical Presence Waiver 2023; WIC policy memo 2023-6

Issued: 05/2023

Effective: 10/2023

Policy:

The local agency (LA) may issue a temporary certification for a 30-day period if an applicant can provide two out of the three required proof documents to determine eligibility (i.e., identification, residency and income).

Procedures:

Participant eligibility
1. The LA must verify identity, residency and income using acceptable forms of documentation from the applicant or participant.
2. The LA shall inform the applicant, participant, authorized representative or alternate representative of the need for proof of identity, proof of residency and proof of income for the applicant or participant when scheduling a certification appointment.
Temporary certification
1. A temporary (30-day) certification may be granted to applicants who provide two out of the three documents to determine eligibility (i.e., identity, residency and income).
2. The LA shall provide the following options:
  1. If all other eligibility requirements are met:
    1. The LA shall mark the appropriate pending proof option in MOWINS and provide food benefits for only the current month’s food package. The LA shall not issue more than 30 days’ worth of food benefits if there is pending proof.
    2. The LA shall provide the applicant, participant, authorized representative or alternate representative an opportunity to provide the missing proof, either hard copy or electronic, within 30 days.
    3. There are no exceptions to the 30-day limit.
  2. Inform the applicant, participant, authorized representative or alternate representative of the required documents and schedule a new certification appointment within the timeframes for meeting certification processing standards. Refer to policy 8.1.110.
3. This procedure does not apply to individuals where no proof exists. Refer to policies 8.1.120, 8.1.130 or 8.1.210.
4. The individual shall be determined ineligible if the applicant fails to provide the missing documentation within the 30-day limit. Refer to policies 8.1.170 and 11.1.030.
  1. Participants certified using a temporary certification shall not receive a consecutive subsequent certification.
    1. If the applicant reapplies within six months of the start of a temporary certification, the applicant cannot be certified without all required proof documents to determine eligibility (i.e., identity, residency and income).

8.1.280 Remote Services

Effective: 10/2025

Issued: 08/2023

Authority references: ARPA Physical Presence Waiver 2023; WIC policy memo 2023-6

Policy:

The local agency (LA) may provide WIC services through a variety of methods, such as in person, over the phone or via a secured online platform to applicants, participants, authorized representatives or alternate representatives. These services include certification eligibility, nutrition assessment, nutrition education, breastfeeding support and referrals.

In-person services must be provided for certain initial certification appointments. The LA competent professional authority (CPA) or nutritionist may use professional judgment to determine if in-person services would enhance participant outcomes.

The LA must provide in-person services if requested.

Remote services must be conducted in a confidential manner using secure electronic means.

Food benefits may be issued remotely to eligible participants.

Identity verification is required before providing WIC services, food instruments and food benefits regardless of service delivery method (e.g., remote or in-person).

Procedures:

Certifications.
1. Initial certification appointments.
  1. The nutrition assessment, nutrition education and referral process must be provided in person for initial certifications unless an exemption applies, or the specific criteria listed within this policy are met.
  2. All infants must be physically present at the initial certification visit unless the following applies:
    1. An exemption that is included in policy 8.1.060.
  3. Children over one year of age must be physically present for the initial certification unless one of the following applies:
    1. The child was certified in Missouri as an infant.
    2. An exemption that is included in policy 8.1.060.
  4. Prenatal women must be physically present at the initial certification appointment unless one of the following applies:
    1. The prenatal woman was certified for WIC in Missouri with a previous pregnancy.
    2. The prenatal woman has a household member (i.e., infant or child) who has received WIC services within the last calendar year.
    3. An exemption that is included in policy 8.1.060.
2. Subsequent certification appointments.
  1. Completion of subsequent certifications may be conducted in person or using a remote service method.
  2. The LA nutritionist or CPA may use professional judgment to determine if a subsequent certification should be completed in person.
3. Certification process.
  1. Proof of income, residency and identity documentation must be verified prior to completing the nutrition assessment, nutrition education and food instrument/food benefit issuance. Refer to policies 8.1.120, 8.1.130, 8.1.210, 8.1.260 and 8.1.270.
  2. Proof documentation:
    1. May be provided in person, by mail or via secured electronic means. Individuals can use a mobile device to present information to the LA (e.g., electric bill, pay stub, immunization record).
    2. May be provided to the LA prior to the certification appointment but must be received and verified on the day of the certification appointment. For documentation time frames, refer to policies 8.1.120, 8.1.130, 8.1.210, 8.1.260 and 8.1.270.
    3. Information provided verbally by phone must be verified with visible proof documentation.
  3. Health referral data (i.e., anthropometrics, health information, immunization records) may be provided to the LA 60 days prior to the certification appointment or sent to the clinic by mail or secured electronic means. The LA may also contact local public health agencies (LPHAs) or health care providers to obtain data if permission to do so was granted by the participant or legal guardian. Refer to policies 8.1.010, 8.1.020 and 8.1.070.
    1. The LA must attempt to collect bloodwork (i.e., hemoglobin) and anthropometric (i.e., height and weight) data at certification and mid-certification, but if unable, the LA must attempt to collect data prior to issuing additional benefits.
    2. Anthropometric data provided to the LA must not be older than 60 days and should reflect current health and categorical status.
    3. Bloodwork (i.e., hemoglobin) data provided to the LA must not be older than 90 days. If bloodwork data is not collected, the LA must attempt to collect data prior to issuing additional benefits.
    4. The LA must place the participant or applicant on a monthly issuance cycle until health referral data is submitted to the LA or collected in person at the clinic.
  4. Voter registration.
    1. Applicants and participants must be provided the opportunity to register to vote regardless of service delivery method (e.g., remote or in-person).
    2. The LA must offer a voter registration form to each applicant, participant, authorized representative or alternate representative prior to or on the day of the certification appointment and any time there is an address or name change. The voter registration form may be provided in person or mailed. Refer to policy 8.1.150.
    3. The LA may provide a link to the Secretary of State’s office website for an applicant or participant to complete the voter registration process online .
    4. The information listed on the declination form (the back of the application) must be provided to the participant. If completed remotely, LA staff may complete the declination form based on the participant’s response. Include “requested to complete online” or “mailed to the participant,” the LA staff’s initials, household ID and date on the form.
    5. The LA must provide the same level of assistance to applicants and participants completing the voter registration form in person or via a remote method unless they refuse assistance.
4. Signature requirements.
  1. The LA may use various methods to collect and maintain participant signatures, including, but not limited to, in person, by mail, or via secured electronic means (e.g., a digital signature platform). Refer to policy 3.1.050.
    1. The participant’s rights and responsibilities must be provided to applicants, participants, authorized representatives or alternate representatives prior to or on the day of the certification appointment.
    2. The LA must verify understanding of their rights and responsibilities before or on the day of the certification appointment.
    3. The LA must obtain a signature on the participant’s rights and responsibilities prior to the end of the certification appointment and before benefit issuance.
5. Authorized representatives, alternate representatives and proxies.
  1. Changing authorized representatives may be done remotely and requires the following:
    1. Documentation indicating or requesting a change to the authorized representative provided in person, by mail or secured electronic means. Refer to policy 8.1.190.
  2. Changing alternate representatives or proxies may be done remotely and requires the following:
    1. A signed written note or verbal request from the current authorized representative. For verbal requests completed over the phone, verify the authorized representative’s name, date of birth (DOB) and zip code. Request a signed written note be sent with the alternate representative or proxy if LA staff cannot verify the authorized representative is submitting the phone request. Refer to policy 8.1.200.
    2. A completed WIC-33. Refer to policy 8.1.190.
6. Notification of ineligibility, termination and expiration of certification.
  1. The LA must provide written notification of ineligibility or termination to the applicant, participant, authorized representative or alternate representative at certification or as required in policy 8.1.170.
  2. The LA may verbally notify the individual of ineligibility initially by phone or secured electronic means, but the Notice of Ineligibility or Termination (WIC-19) must be provided either in person, by mail or by secured electronic means.
Nutrition services.
1. The nutrition assessment at certification or mid-certification must be completed prior to providing nutrition education and referrals. Nutrition assessment, nutrition education and referrals must be completed on the same day.
  1. Nutrition education provided at initial certifications must be completed in person.
  2. All subsequent nutrition education appointments may be offered via remote platforms or in person at the discretion of the LA nutritionist or CPA.
    1. If the appointment is conducted remotely, the LA must provide a secure video option if requested by the participant.
  3. Resources (e.g., pamphlets, newsletters, public service announcements, TV advertisements and take-home activities) may be provided remotely via secured electronic means in order to reinforce nutrition education messages provided by the professional staff. Refer to policy 2.4.110.
2. Referral information may be provided to participants through secured electronic means, in person or by mail.
  1. Participant consent is required to send referrals directly to other services.
  2. If signatures are required for referrals, the form may be provided by mail or via secured electronic means (e.g., Adobe PDF).
3. Remote or in-person services may be appropriate for high-risk participants at the discretion of the LA nutritionist.
4. Remote or in-person services may be appropriate for breastfeeding participants at the discretion of the WIC-designated breastfeeding expert.
Food instrument and food benefit issuance.
1. The authorized representative, alternate representative or proxy must sign for receipt of food instruments issued by the LA. Refer to policy 1.1.030.
2. Food instruments and food benefits must be provided and issued after the certification eligibility (i.e., proof documentation), nutrition assessment, nutrition education and food package tailoring are complete.
  1. The individual must sign for the participant’s rights and responsibilities before food benefits are issued. Refer to policy 8.1.080.
3. Food instruments and food benefits must be issued and provided on the day of the certification appointment.
Documentation of remote certifications in the Management Information System (MIS).
1. All information and documents (e.g., health referral data, personal identifiable information) transmitted, received or stored must be kept secure when using an electronic or digital platform.
  1. Once the information has been entered into the MIS, the information must be deleted from the digital platform.
2. The LA must:
  1. Begin the certification process (i.e., certification guided script) in the MIS at the time of the in-person or remote certification appointment.
  2. Begin the certification process in the MIS once all proof documentation is received.
    1. Notate in a general note if documentation was received prior to the certification appointment.
    2. For temporary certification requirements, refer to policy 8.1.270.
  3. Notate in the MIS demographic screen if an applicant or participant is physically present at the certification appointment.
  4. Document each attempt to collect missing health referral data in an alert and copy it to a general note that indicates the data that needs to be collected and the reason it was unsuccessful.
    1. The LA must notate in the MIS height, weight and bloodwork section when health referral data is obtained from an outside source.
    2. Once anthropometric or bloodwork data is obtained, if additional risk factors are assigned, the LA nutritionist or CPA must follow up prior to providing additional benefits to reassess and tailor nutrition services.
Reports and tracking.
1. The LA must follow the separation of duties procedures when completing remote certifications. Refer to policy 8.1.030.
2. The LA must provide appropriate follow-up for individuals who do not show up or miss a remote appointment. Refer to policy 7.1.030.
3. The LA must indicate in WebGrants if their agency is conducting remote services.

WIC Operations Manual (WOM)

VIII. Certification Eligibility and Coordination of Services

8.1.010 Participant Confidentiality

Policy:

Procedures:

8.1.020 Participant Referrals

Policy:

Procedures:

8.1.030 Conflict of Interest and Separation of Duties

Policy:

Procedures:

8.1.040 Value of WIC Benefits

Policy:

Procedures:

8.1.050 Proof of Pregnancy

Policy:

Procedures:

8.1.060 Physical Presence at Certification or Mid-certification Assessment

Policy:

Procedures:

8.1.070 Certification

Policy:

8.1.080 Program Explanation

Policy:

Procedures:

8.1.100 Next Steps for Health (Exit Counseling)

Policy:

Procedures:

8.1.110 Time Frames for Applicant Processing

Policy:

Procedures:

8.1.120 Residency Requirements

Policy:

Procedures:

8.1.130 Income Requirements

Policy:

Procedures:

8.1.140 Determining Household Size

Policy:

Procedures:

8.1.150 Voter Registration

Policy:

Procedures:

8.1.160 Transfer of Certification and Verification of Certification (VOC)

Policy:

Procedures:

8.1.170 Notification of Ineligibility, Termination, or Expiration of Certification

Policy:

Procedures:

8.1.180 Schedule Certification Periods

Policy:

Procedures:

8.1.190 Authorized Representatives and Alternate Representatives

Policy:

Procedures:

8.1.200 Proxies

Policy:

Procedures:

8.1.210 Identity Requirements

Policy:

Procedures:

8.1.240 WIC Shopping Assistant

Policy:

Procedures:

8.1.260 Adjunct Eligibility Requirements

Policy:

Procedures:

8.1.270 Temporary Certification

Policy:

Procedures:

8.1.280 Remote Services

Policy:

Procedures:

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