GP: 1 Certification and Issuing F.I. for Employees and Relatives (New)

Effective Date: 02/01 Downloads: PDF Version    Revised Date: 07/15
   

Policy

To avoid situations with a potential for conflict of interest and/or fraud, local WIC Program staff will not determine eligibility, perform certification, and/or issue food instruments to themselves or any person related to them.

Procedure

Certification of Relatives

  1. Each WIC clinic and agency will meet the following criteria to address situations of staff certifying and/or issuing vouchers to themselves, relatives and close friends. Relatives include, but are not limited to; spouse, parents, children, grandchildren, grandparents, brothers, sisters, aunts, uncles, nieces, nephews, first cousins, in-laws, step-parents, step-children, step-brothers and step-sisters by blood or marriage. Staff should consult with their supervisor if there is a possible conflict with someone not included in the above list.
  2. WIC Clinic staff members must inform their WIC Coordinator, Clinic Nutritionist or Clinic Manager before the certification process begins that they (the staff member), a relative, or close a friend is applying for or receiving benefits from WIC.
  3. Staff members cannot determine any part of the eligibility process for themselves, relatives, or close friends.
    • The WIC employee who is scheduled or has a relative or close friend scheduled for a certification appointment shall notify their WIC director or clinic supervisor to make arrangements for another employee to determine eligibility.
    • In clinics where there are no other trained staff to determine WIC eligibility, a clinic supervisor or manager should complete the certification.
    • In State rural clinics where there is not a direct clinic supervisor or manager to complete the certification the State Point of Contact shall be contacted for assistance.
  4. WIC staff members will not issue food instruments to themselves, members of their relatives or close friends. An unrelated staff person will issue food instruments to these participants.
  5. WIC staff members may provide nutrition education to relatives and close friends.
    • Local agencies shall maintain an updated list of employees on WIC while working for the agency and an updated list of relatives and close friends of employees on the WIC program. The lists must be updated anytime a WIC Coordinator, Clinic Nutritionist or Clinic Manager is notified that a relative or friend is applying or receiving benefits from WIC. See GP: 12. The WIC Coordinator, Clinic Nutritionist or Clinic Manager should review the listed individuals in the MIS system every quarter to maintain program integrity. In the MIS system:
      • Click on the Health Assessment Tab
      • In the member history, review the dates and action codes
      • The staff member should not have any of the following codes for themselves, relatives or close friends
        • A – Add Client
        • H – Infant Health Assessment
        • I – Issue Benefits
        • R – Reinstate
        • S – Re-Certify
        • V – Void Benefits

If the WIC Coordinator, Clinic Nutritionist or Clinic Manager find that WIC staff member is violating the Conflict of Interest policy, the WIC Coordinator, Clinic Nutritionist or Clinic Manager needs to submit a corrective action plan with documented discipline for the staff member.