GP: 11 Staff Fraud and Abuse
|Effective Date: 07/09||Downloads: PDF Version||Revised Date: 07/15|
To prevent and detect staff fraud and abuse
To ensure that no conflict of interest exists, local agency employees shall not:
- Participate in any component of the certification process and issuing benefits to himself/herself, relatives and close friends
- Determining eligibility for all certification criteria and issuing benefits for the same participant (separation of duties)
- Having financial interest in any food vendor who is authorized to accept WIC food instruments
Alleged WIC Program abuse by staff shall be reported to the appropriate Local Agency and State Agency staff for investigation and resolution.
I. Local Agencies shall adhere to procedures to prevent and detect staff fraud and abuse. At a minimum the procedure shall include the following:
a. Requirements for logging off computers and not sharing computer passwords
b. An annual requirement for the Local Agency employees to sign and date a locally produced form each fiscal year, which contains the following statements:
“I certify that neither I nor any individual related to me by marriage or blood has any financial interest as owner, officer, director, or partner in any food vendor who is authorized to accept WIC food instruments. I certify that I will not participate in any component of the certification process and issue food benefits, at certification, to myself, a relative, or a close friend”
The signed and dated statement must be maintained on file and made available for audit/review. See GP: 12
The form needs to be updated anytime a WIC staff member notifies their supervisor that themselves, a relative or close friend is applying for or receiving benefits at the clinic.
c. A WIC employee who is scheduled or who has a relative or close friend scheduled for a certification appointment shall notify the WIC director or clinic supervisor so that arrangements can be made for another WIC employee to certify and/or issue the food instruments. WIC employees may only provide nutrition education to relatives and close friends.
d. Procedures for circumstances when separation of duties is not possible because only one employee is available to conduct certifications or no certifier is available. The procedures shall include the following:
i. Reschedule certification appointments
ii. The WIC director or clinic supervisor will make arrangements for an employee from another clinic to serve as a second person involved in the certification process
iii. If another employee is not available, the Local Agency shall keep all documentation on participants’ files. A supervisory review of all participant records certified and benefits issued by the one staff member on that particular day(s). The record review shall be completed within 30 days. If more than ten participants were certified, the record review shall include a random sample of a minimum of 10 records or 20% (whichever is greater) of the records.
iv. A system for documenting, reporting and follow-up of suspected/alleged abuse, including State Agency notification
v. Procedures for referring any case for criminal prosecution
e. Failure to follow these procedures may cause the Local Agency to assume the liability for the amount of improperly issued benefits
f. Any exceptions to this policy can be requested to the State Agency for approval. Required documentation to the procedures in this policy may be made requested for review during management evaluations.