GP: 2 Separation of Duties in WIC Clinic Operations (New)
|Effective Date: 10/09||Downloads: PDF Version||Revised Date: 06/18|
Separation of Duties (SOD) occurs during certification and re-certification appointments and is a standard accountability/security practice used in any operation in which valuable benefits change hands. At a minimum, Local Agencies (L.A.) shall ensure income eligibility determination and medical or nutrition risk assessment procedures consist of at least two separate and distinct functions performed by two different staff members.
Whenever possible WIC local agencies will separate WIC certification elements relative to staff roles and responsibilities (GP: 9). For example:
- Staff #1- WIC Clerk or CPA 1: perform partial eligibility determination and input in the Family/Intake Panel in NV WISH:
- Income Eligibility (determine adjunct eligibility, determine income, pay frequency, economic unit, etc.)
- Staff #2- CPA 2: Determines remaining certification elements and performs education and care. The following panels in the NV WISH System:
- Nutrition Risk Assessment
- Nutrition and Breastfeeding Education and Care
- Food Benefit Issuance
The following is taken from the USDA/FNS Memo #2016-5 regarding SOD at WIC Local Agencies:
“It is critically important to target our efforts in areas that may be susceptible to fraud or abuse. Therefore, at a minimum the staff person who determines income eligibility and medical or nutritional risk cannot be the same person. Either person may issue food benefits.”
The following functions are required for a local agency to maintain program integrity. Please note the following procedure relates solely to certification and recertification appointments. SOD is not necessary at second nutrition education contacts/classes, high risk appointments, or infant and child health assessments.
Whenever two or more L.A. staff members are present, the L.A. must always follow separate duties when determining income eligibility and determining medical or nutritional risk. The staff person who determines income eligibility and medical or nutrition risk cannot be the same person
Alternate Procedures to Separation of Duties for One Person Clinics and Two Person Clinics Where Separation of Duties is Not Possible
PLEASE NOTE: Local Agencies with only one (1) staff member are not allowed to certify oneself, relatives or close friends. Certifications for people in this category must be done by the Local Agency director or the director’s designee. Please see GP: 1 for further detail.
If a local agency finds they cannot achieve SOD, a review of those certification records when SOD did not occur is required. Local agencies will implement the following based on clinic staffing and capabilities:
- Local Agencies that have clinics with only one (1) staff person available to determine WIC eligibility criteria is also required to designate an individual other than the certifier (e.g. the WIC Local Agency Director) to perform a post review of Certification records. The designated staff will review all non-SOD compliant, non-breastfeeding infant certification records and a 20 percent random sample of the remaining non-SOD compliant certification records within two (2) weeks from the date of certification. A non- breastfeeding infant is an infant issued ANY quantity of formula at Certification.
- If the local agency is unable to perform both SOD and the post record review because supervising staff also provides direct WIC services (determining eligibility, determining nutrition risk, issuing benefits), the agency will secure arrangements with the State Agency to perform the post review.
- Local Agencies with more than one WIC staff available, but SOD is still not possible, must also designate an individual other than the certifier (e.g. the WIC Local Agency Director) to perform a post review of non-SOD compliant records. The designated staff will review all (non-SOD) non-breastfeeding infant certification records and a 20 percent random sample of the remaining non-SOD certification records within two (2) weeks from the date of certification. A non- breastfeeding infant is an infant issued ANY quantity of formula at Certification. Additionally, a review of 10 percent of each clinic’s non-SOD compliant certification records must also be conducted every six months by the WIC Local Agency Director or designee. Households previously contacted with Customer Service calls can be contacted again via phone (e.g. to check in, confirm appointment, request feedback etc.) or via performing a chart audit in WISH. If a clinic only has one staff person, the additional file review of 10 percent of the clinic’s certifications every six months is not required.
Monitoring of Staff to Prevent and Detect Fraud
To ensure a single staff member does not determine program eligibility for all certification criteria and medical/nutrition risk for the same participant:
- Employee permissions will be set within the NV WISH system to allow appropriate access to certification and medical/nutrition risk determination functions.
a. Staff working in clinics where SOD cannot occur will be approved for security access within NV WISH by the State WIC Director that would allow the staff person to complete intake screens, nutrition assessment and issue benefits. However, when possible, staff should avoid completing both the income eligibility determination and the nutrition risk assessment for the same participant.
b. Using the WIC Separation of Duties Audit Tool Log (Appendix GP-C) the L.A. WIC Director or Manager will complete the following procedure for:
i. All non-SOD compliant, non-breastfeeding infant certification records.
ii. At least 20 percent of a random sample of all remaining non-SOD compliant certifications on bi-weekly basis
iii. At least 10 percent each clinic’s non-SOD compliant certification records must also be conducted every six months
c. A telephone call must be made to the participant to validate the information recorded in the system and verify participation. This call may be identified as a customer service survey call.
i. Record date of certification
ii. Record the staff person’s name
iii. Record the participant name and family ID number of the families listed on the report.
iv. Telephone contact with participant to ask valid questions relating to certification, i.e. “How was your WIC appointment at your WIC Clinic on [date]” and “Can you verify your address.”
v. If unable to reach participant, review the records in NV WISH to look for potential violations of policy or indications of fraud of the program.
vi. If income documentation is available, this is reviewed.
vii. The WIC director signs the log, verifying that no indications of potential fraud or abuse were detected, or if detected, were properly reported and investigated.
viii. Maintain the log on file at the local agency and email a copy of the WIC Separation of Duties Audit Tool Log to the State WIC Office at: WICGeneral@health.nv.gov to keep on file at the state.
d. Local agencies are to retain copies of all reports for three years. These reports will be reviewed during the Local Agency Biennial Program Review.